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...
Seizure of cash in election by ECI - IT Dept. has completely failed to appreciate that neither the seizure was u/s 132 nor the pre-requisite to an exercise of search and seizure u/s 132 were satisfied nor the requisition satisfies the provisions of Section 226(3), which is the only provision enabling the IT Dept. to take over the money apart from the search and seizure - directed to refund with interest @ 10%
Seizure of cash in election by ECI - IT Dept. has completely failed to appreciate that neither the seizure was u/s 132 nor the pre-requisite to an exercise of search and seizure u/s 132 were satisfied nor the requisition satisfies the provisions of Section 226(3), which is the only provision enabling the IT Dept. to take over the money apart from the search and seizure - directed to refund with interest @ 10%
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