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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Exemption u/s 11 - Cancellation of registration u/s. 12AA post survey - Assessee contended that survey proceedings gets abated after search and assessment u/s 153A - even assuming proceedings had been initiated for the purpose of completing an assessment or re-assessment as a consequence of the survey, even those proceedings would stand abated as on the date of search. Thus clearly there is no assessment order nor any evidence specifically conclusively found or established against the assessee on the issues raised by the Ld. CIT(E) by an order of any quasi-judicial authority nor has the violation of any other law reached finality - AT
Exemption u/s 11 - Cancellation of registration u/s. 12AA post survey - Assessee contended that survey proceedings gets abated after search and assessment u/s 153A - even assuming proceedings had been initiated for the purpose of completing an assessment or re-assessment as a consequence of the survey, even those proceedings would stand abated as on the date of search. Thus clearly there is no assessment order nor any evidence specifically conclusively found or established against the assessee on the issues raised by the Ld. CIT(E) by an order of any quasi-judicial authority nor has the violation of any other law reached finality - AT
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