Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Condonation of delay - to seek that the period of limitation provided in the statute be ignored in case of Revenue's appeals cannot be accepted. The Appeals which are filed by the Revenue in this Court under Section 260A of the Act are very large in number and on an average over 2000 per year from the orders of the Tribunal. Thus, the officers of the Revenue should be well aware of the statutory provisions and the period of limitation and should pursue its remedies diligently. - HC
Condonation of delay - to seek that the period of limitation provided in the statute be ignored in case of Revenue's appeals cannot be accepted. The Appeals which are filed by the Revenue in this Court under Section 260A of the Act are very large in number and on an average over 2000 per year from the orders of the Tribunal. Thus, the officers of the Revenue should be well aware of the statutory provisions and the period of limitation and should pursue its remedies diligently. - HC
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