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...
Condonation of delay in filing of appeal before CIT (A) - In the case in hands, the branch has to act as per advice of Head Office, hence, which consumed sufficient period of time, therefore, it could not be regarded as negligence or of lacking of bona-fides. We are of the considered opinion that CIT (A) was not justified in refusing to condone the delay in filing of appeal - Delay condoned.
Condonation of delay in filing of appeal before CIT (A) - In the case in hands, the branch has to act as per advice of Head Office, hence, which consumed sufficient period of time, therefore, it could not be regarded as negligence or of lacking of bona-fides. We are of the considered opinion that CIT (A) was not justified in refusing to condone the delay in filing of appeal - Delay condoned.
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