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...
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Power of commissioner (appeals) to remand back the case - The order under challenge is not either of the one as is mentioned in sub clause (3) of Section 35A. It is precisely an order of remand which power stand withdrawn from Commissioner (Appeals). This order from no sense of interpretation can be held to have been passed either under the power of annulling or the power of confirming or the power of modifying - Commissioner (Appeals) is directed to adjudicate the same on merits - AT
Power of commissioner (appeals) to remand back the case - The order under challenge is not either of the one as is mentioned in sub clause (3) of Section 35A. It is precisely an order of remand which power stand withdrawn from Commissioner (Appeals). This order from no sense of interpretation can be held to have been passed either under the power of annulling or the power of confirming or the power of modifying - Commissioner (Appeals) is directed to adjudicate the same on merits - AT
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