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...
Lifting of provisional attachment - It is held that under sub-section (2) of Section 83, a provisional attachment ceases to have effect upon the expiry of the period of one year of the order being passed under sub-section (1). The power to levy a provisional attachment has been entrusted to the Commissioner during the pendencdy of proceedings under Sections 62, 63, 64, 67, 73 or as the case may be, Section 74. - HC
Lifting of provisional attachment - It is held that under sub-section (2) of Section 83, a provisional attachment ceases to have effect upon the expiry of the period of one year of the order being passed under sub-section (1). The power to levy a provisional attachment has been entrusted to the Commissioner during the pendencdy of proceedings under Sections 62, 63, 64, 67, 73 or as the case may be, Section 74. - HC
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