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 - payment of conversion charges and job charges to related parties u/s 40A(2)(a) thoroughly examined by the AO - CIT had only tried to substitute his knowledge in technical aspect of the industry thereby trying to substitute his opinion on the impugned issue as against the opinion already framed by the AO - not permissible
Revision u/s 263 - payment of conversion charges and job charges to related parties u/s 40A(2)(a) thoroughly examined by the AO - CIT had only tried to substitute his knowledge in technical aspect of the industry thereby trying to substitute his opinion on the impugned issue as against the opinion already framed by the AO - not permissible
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