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 - Income deemed to accrue or arise in India - writ against the show cause notice - Looking into the spirit of Section 9(1)(i) of the Act, in the context of the contents made in the show cause notice, it is sufficient to form an opinion that the matter requires effective and elaborate adjudication in order to cull out the truth with reference to the pleadings and grounds raised by the petitioner. - HC
Reopening of assessment u/s 147 - Income deemed to accrue or arise in India - writ against the show cause notice - Looking into the spirit of Section 9(1)(i) of the Act, in the context of the contents made in the show cause notice, it is sufficient to form an opinion that the matter requires effective and elaborate adjudication in order to cull out the truth with reference to the pleadings and grounds raised by the petitioner. - HC
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