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...
Reassessment u/s 148 - exemption u/s 10AA - assessment completed u/s 143(3) reopened after expiry of 4 years - Revenue could not place any material to establish that there is a failure on the part of the assessee to disclose all material facts required for assessment - Reassessment invalid
Reassessment u/s 148 - exemption u/s 10AA - assessment completed u/s 143(3) reopened after expiry of 4 years - Revenue could not place any material to establish that there is a failure on the part of the assessee to disclose all material facts required for assessment - Reassessment invalid
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