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 - it filed appeal against the assessment order instead of 154 order passed by the Assessing Officer because the scope in challenging the assessment order in appeal is far more wider than challenging the order passed under Section 154 of the Income-tax Act for rectification of any mistake. Since the assessee has availed one of the courses available to it and this has made its appeal time barred, it is a plausible explanation for condonation of delay. - Delay condoned - AT
Condonation of delay - it filed appeal against the assessment order instead of 154 order passed by the Assessing Officer because the scope in challenging the assessment order in appeal is far more wider than challenging the order passed under Section 154 of the Income-tax Act for rectification of any mistake. Since the assessee has availed one of the courses available to it and this has made its appeal time barred, it is a plausible explanation for condonation of delay. - Delay condoned - AT
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