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...
Reassessment u/s 147/148 - Initiation of rectification u/s 154 by the AO and simultaneously initiating the reassessment u/s 147/148 on the same reasons, particularly when there is no failure on the part of the assessee to fully and truly disclose all material facts necessary for assessment, are not sustainable in the eyes of law and is liable to be quashed
Reassessment u/s 147/148 - Initiation of rectification u/s 154 by the AO and simultaneously initiating the reassessment u/s 147/148 on the same reasons, particularly when there is no failure on the part of the assessee to fully and truly disclose all material facts necessary for assessment, are not sustainable in the eyes of law and is liable to be quashed
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