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...
Validity of notice issued for re-assessment - satisfaction of requirement of section 151(2) before issuance of notice u/s 148 - it was a fit case for issuance of notice u/s 148 - Merely because the papers were thereafter for some erroneous reason also placed before the Commissioner who also recorded his similar satisfaction would not take away anything from the previous conclusion. - HC
Validity of notice issued for re-assessment - satisfaction of requirement of section 151(2) before issuance of notice u/s 148 - it was a fit case for issuance of notice u/s 148 - Merely because the papers were thereafter for some erroneous reason also placed before the Commissioner who also recorded his similar satisfaction would not take away anything from the previous conclusion. - HC
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