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...
Validity of reopening of assessment - Entire attempt of the assessing officer was to hold that the expenditure incurred, in respect of which details are already available on record and was examined in original assessment, as capital expenditure and such opinion is solely based out of the opinion of the audit party, which in itself is not permissible. The reassessment is bad in law - AT
Validity of reopening of assessment - Entire attempt of the assessing officer was to hold that the expenditure incurred, in respect of which details are already available on record and was examined in original assessment, as capital expenditure and such opinion is solely based out of the opinion of the audit party, which in itself is not permissible. The reassessment is bad in law - AT
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