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...
Validity of assessment made under Section 143(1) instead of section 153C - In the facts of the present appeal, undisputedly, the books of account/documents/assets found during the search and seizure operation were received by the AO having jurisdiction over the assessee - Neither the AO has recorded any satisfaction nor issued any notice as contemplated under section 153C - The impugned assessment order passed under section 143(3) of the Act is invalid. - AT
Validity of assessment made under Section 143(1) instead of section 153C - In the facts of the present appeal, undisputedly, the books of account/documents/assets found during the search and seizure operation were received by the AO having jurisdiction over the assessee - Neither the AO has recorded any satisfaction nor issued any notice as contemplated under section 153C - The impugned assessment order passed under section 143(3) of the Act is invalid. - AT
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