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 - defective return of income u/s 139(9) - non filing of Audit report with the ITR - setoff of carry forward of loss - the assessee itself has removed the defect without being intimated by the AO - Since the assessee has already filed the audit report, there is no question of AO issuing a defect notice - Revision proceedings are invalid.
Revision u/s 263 - defective return of income u/s 139(9) - non filing of Audit report with the ITR - setoff of carry forward of loss - the assessee itself has removed the defect without being intimated by the AO - Since the assessee has already filed the audit report, there is no question of AO issuing a defect notice - Revision proceedings are invalid.
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