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...
Rectification u/s 254 - in the earlier years same issue had been sent back to the A.O. for verification and adjudication in the light of the findings of the Hon'ble High Court - since CIT(A) himself made verification in accordance with the findings of the Hon'ble High Court in presnt appeal, ITAT dismissed the appeal of revenue - no error in the order of the I.T.A.T.
Rectification u/s 254 - in the earlier years same issue had been sent back to the A.O. for verification and adjudication in the light of the findings of the Hon'ble High Court - since CIT(A) himself made verification in accordance with the findings of the Hon'ble High Court in presnt appeal, ITAT dismissed the appeal of revenue - no error in the order of the I.T.A.T.
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