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 accrued in India - It is also not understood as to how the appellant-Revenue can contend that the respondent-assessee does not have PE in India for the purpose of 201 proceedings in the case of LGEIL but would have a PE as far as its own taxability is concerned for the same Assessment Year. - Moreover, in view of the decision of the Apex Court, the proceedings initiated by the appellant-Revenue has become infructuous and accordingly ex debito justitiae - HC
Reopening of assessment u/s 147 - Income accrued in India - It is also not understood as to how the appellant-Revenue can contend that the respondent-assessee does not have PE in India for the purpose of 201 proceedings in the case of LGEIL but would have a PE as far as its own taxability is concerned for the same Assessment Year. - Moreover, in view of the decision of the Apex Court, the proceedings initiated by the appellant-Revenue has become infructuous and accordingly ex debito justitiae - HC
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