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...
Revision u/s 263 - merger of appellate order - very issue which was considered by the CIT(A) and concluded was reopened - no scope for re-examination in the jurisdiction u/s 263 as the assessment order has merged in the appellate order.
Revision u/s 263 - merger of appellate order - very issue which was considered by the CIT(A) and concluded was reopened - no scope for re-examination in the jurisdiction u/s 263 as the assessment order has merged in the appellate order.
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