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...
Reference the matter to the larger bench of 3 members by the Single Member Bench - Even if the learned Member hearing this appeal found it difficult to accept the view taken by the Division Benches of the Tribunal, then too the matter could have been placed only before two Members of the Tribunal, who could then have examined whether the matter require re-consideration by a Larger Bench of three Members of the Tribunal. - AT
Reference the matter to the larger bench of 3 members by the Single Member Bench - Even if the learned Member hearing this appeal found it difficult to accept the view taken by the Division Benches of the Tribunal, then too the matter could have been placed only before two Members of the Tribunal, who could then have examined whether the matter require re-consideration by a Larger Bench of three Members of the Tribunal. - AT
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