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...
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Validity of assessment u/s 153A instead of u/s 153C - neither a search was initiated u/s 132 nor books of account, other documents or any assets were requisitioned u/s 132A against the assessee. - the notice U/s 153A issued to the assessee was without jurisdiction
Validity of assessment u/s 153A instead of u/s 153C - neither a search was initiated u/s 132 nor books of account, other documents or any assets were requisitioned u/s 132A against the assessee. - the notice U/s 153A issued to the assessee was without jurisdiction
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