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...
Reopening of assessment u/s 147 - non-deduction of TDS as mentioned in the Form no. 3CD Tax Audit Report u/sec. 44AB - the assessee has filed the details and disclosed fully and truly all material facts relevant to the assessment year in consideration. - the assessment was reopened beyond a period of four years and cannot be sustained. - AT
Reopening of assessment u/s 147 - non-deduction of TDS as mentioned in the Form no. 3CD Tax Audit Report u/sec. 44AB - the assessee has filed the details and disclosed fully and truly all material facts relevant to the assessment year in consideration. - the assessment was reopened beyond a period of four years and cannot be sustained. - AT
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