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...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Revision u/s 263 - the head of assessee’s income derived from its holiday homes i.e. whether it is income from house property as per the PCIT, business income going by the AO in assessment and the CIT(A) and the residuary had of “other” sources in its computation; respectively, is purely a debatable issue. - Assumption of jurisdiction u/s 263 is not proper.
Revision u/s 263 - the head of assessee’s income derived from its holiday homes i.e. whether it is income from house property as per the PCIT, business income going by the AO in assessment and the CIT(A) and the residuary had of “other” sources in its computation; respectively, is purely a debatable issue. - Assumption of jurisdiction u/s 263 is not proper.
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