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 - Ld. CIT without pointing out any infirmity in the reply /explanation of the assessee could not concluded that the assessment order passed by the AO was found to be ‘erroneous and prejudicial to the interest of revenue’ - explanation-2(a) to section 263 does not authorize or give unfettered powers to the Commissioner to revise each and every order
Revision u/s 263 - Ld. CIT without pointing out any infirmity in the reply /explanation of the assessee could not concluded that the assessment order passed by the AO was found to be ‘erroneous and prejudicial to the interest of revenue’ - explanation-2(a) to section 263 does not authorize or give unfettered powers to the Commissioner to revise each and every order
Note: It is a system-generated summary and is for quick reference only.