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 assessment - non-service of the notice u/s.143(2) - It is also clear from the record that the assessee has raised this issue first time before us, however, the documents which were produced before us, did not speak that the assessee has raised this issue before the lower authorities. CIT DR has produced sufficient evidences for substantiating the case in favour of Revenue - Argument of assessee rejected - AT
Validity of assessment - non-service of the notice u/s.143(2) - It is also clear from the record that the assessee has raised this issue first time before us, however, the documents which were produced before us, did not speak that the assessee has raised this issue before the lower authorities. CIT DR has produced sufficient evidences for substantiating the case in favour of Revenue - Argument of assessee rejected - AT
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