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...
Reassessment of a case beyond 6 years - directions were issued u/s 150(1) - adequate opportunity of hearing to the concerned party was not given - The directions issued by the CIT (A) insofar as it records adverse findings, is hereby quashed. In case, the CIT(A) wishes to proceed against the petitioner, he shall do so provided he shall issue appropriate notice in that regard.
Reassessment of a case beyond 6 years - directions were issued u/s 150(1) - adequate opportunity of hearing to the concerned party was not given - The directions issued by the CIT (A) insofar as it records adverse findings, is hereby quashed. In case, the CIT(A) wishes to proceed against the petitioner, he shall do so provided he shall issue appropriate notice in that regard.
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