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...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Time Limitation - appeal stands filed after the normal period of three months provided for filing an appeal as also even after the extended period of three months for which the Commissioner (Appeals) is empowered to condone the delay - the time period of filing appeal has to be reckoned from the date of rejection of ROM Application.
Time Limitation - appeal stands filed after the normal period of three months provided for filing an appeal as also even after the extended period of three months for which the Commissioner (Appeals) is empowered to condone the delay - the time period of filing appeal has to be reckoned from the date of rejection of ROM Application.
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