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 - bogus purchases - documents like invoices, given details of stocks, payments through the banking channels and confirmation from parties examined by AO - before revising the assessment u/s 263, the CIT ought to have made some inquiry of his own such as noticed u/s 133(6) or examination of concerned parties declared as hawala parties - revision quashed
Revision u/s 263 - bogus purchases - documents like invoices, given details of stocks, payments through the banking channels and confirmation from parties examined by AO - before revising the assessment u/s 263, the CIT ought to have made some inquiry of his own such as noticed u/s 133(6) or examination of concerned parties declared as hawala parties - revision quashed
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