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...
Transfer of case - Validity of the assessment orders passed by the Additional CIT u/s 143(1) - Lack of inherent jurisdiction - The assessment order has been passed by the Addl.CIT without any transfer of jurisdiction in his favour - the assessment order passed by him u/s 143(3) is without jurisdiction, illegal, bad in law and hence ought to be quashed. - AT
Transfer of case - Validity of the assessment orders passed by the Additional CIT u/s 143(1) - Lack of inherent jurisdiction - The assessment order has been passed by the Addl.CIT without any transfer of jurisdiction in his favour - the assessment order passed by him u/s 143(3) is without jurisdiction, illegal, bad in law and hence ought to be quashed. - AT
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