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...
Jurisdiction of AO - transfer of case u/s 127 - AO at Kurnool had transferred the file to the AO at Hyderabad - only the Pr. Director General or the Pr. CIT or Pr. CIT can transfer the case u/s 127 - issuance u/s 143(2) by the Dy. CIT (IT)-1, Hyderabad is without any authority and also beyond the period of six months from the date of filing of returns
Jurisdiction of AO - transfer of case u/s 127 - AO at Kurnool had transferred the file to the AO at Hyderabad - only the Pr. Director General or the Pr. CIT or Pr. CIT can transfer the case u/s 127 - issuance u/s 143(2) by the Dy. CIT (IT)-1, Hyderabad is without any authority and also beyond the period of six months from the date of filing of returns
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