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...
Validity of reopening of assessment u/s 147 - sale of immovable property - In the absence of any development during this intervening period of one year from the date of purchase and till the date of sale, the appreciation of value from ₹ 4.00 lacs to ₹ 38.50 lacs indicates the involvement of the parties in mischievous acts of showing the minimum amount of purchase consideration by the assessee in comparison to the sale consideration shown in the sale agreement. - AT
Validity of reopening of assessment u/s 147 - sale of immovable property - In the absence of any development during this intervening period of one year from the date of purchase and till the date of sale, the appreciation of value from ₹ 4.00 lacs to ₹ 38.50 lacs indicates the involvement of the parties in mischievous acts of showing the minimum amount of purchase consideration by the assessee in comparison to the sale consideration shown in the sale agreement. - AT
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