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...
Reopening of assessment -Notice u/s 143(2) - AO given the notices u/s 143(2) to the assessee immediately to filing the return, which shows non-application of mind on the part of the of the AO. Therefore, notice under section 143(2) is invalid and resultantly, the assessment is vitiated and is liable to be quashed.
Reopening of assessment -Notice u/s 143(2) - AO given the notices u/s 143(2) to the assessee immediately to filing the return, which shows non-application of mind on the part of the of the AO. Therefore, notice under section 143(2) is invalid and resultantly, the assessment is vitiated and is liable to be quashed.
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