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 Search u/s 132 - suppression of income as the profit declared is contrary to the actual profit received. - The power for re-assessment is no doubt a remedy available to the Authority but in light of the information as detailed in the note, grounds have been made out for exercise of power u/s 132(c) in the present case and it cannot be said that the said action is either malafide/ arbitrary/ capricious. - HC
Validity of Search u/s 132 - suppression of income as the profit declared is contrary to the actual profit received. - The power for re-assessment is no doubt a remedy available to the Authority but in light of the information as detailed in the note, grounds have been made out for exercise of power u/s 132(c) in the present case and it cannot be said that the said action is either malafide/ arbitrary/ capricious. - HC
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