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 - specified domestic transactions - effect of omission of 92BA(1) w.e.f. 1.4.2017 - the order has been revised purely on the basis that the AO has not referred to determine the ALP to the TPO - Since the provision itself stood omitted at the time when the order was passed by the Pr. CIT, the impugned order cannot be sustained, hence is hereby quashed
Revision u/s 263 - specified domestic transactions - effect of omission of 92BA(1) w.e.f. 1.4.2017 - the order has been revised purely on the basis that the AO has not referred to determine the ALP to the TPO - Since the provision itself stood omitted at the time when the order was passed by the Pr. CIT, the impugned order cannot be sustained, hence is hereby quashed
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