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...
Reopening of assessment u/s 147 - It is sufficient if any one of the conditions stipulated in Proviso clause to Section 147 is satisfied for reopening of assessment. - The sufficiency of the reasons need not be gone into by the High Court in a writ proceedings. Thus, if there is a prima facie case for the purpose of reopening of assessment, and the objective satisfaction is sufficient for the purpose of reopening of assessment. - HC
Reopening of assessment u/s 147 - It is sufficient if any one of the conditions stipulated in Proviso clause to Section 147 is satisfied for reopening of assessment. - The sufficiency of the reasons need not be gone into by the High Court in a writ proceedings. Thus, if there is a prima facie case for the purpose of reopening of assessment, and the objective satisfaction is sufficient for the purpose of reopening of assessment. - HC
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