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...
Failure to comply with directions given to the AO by the appellate authority - Assessing Officer, in a most negligent and mechanical manner, rejected the application of the assessee. Even the CIT(A)/National Faceless Appeal Centre has miserably failed to consider the simple prayer of the assessee and rejected the appeal in a mechanical manner. The assessee thus, has been left to the mercy of the system and has to approach this Tribunal for the simple case that the Assessing Officer may be directed to give appeal effect to the order of the ld. CIT(A). - AT
Failure to comply with directions given to the AO by the appellate authority - Assessing Officer, in a most negligent and mechanical manner, rejected the application of the assessee. Even the CIT(A)/National Faceless Appeal Centre has miserably failed to consider the simple prayer of the assessee and rejected the appeal in a mechanical manner. The assessee thus, has been left to the mercy of the system and has to approach this Tribunal for the simple case that the Assessing Officer may be directed to give appeal effect to the order of the ld. CIT(A). - AT
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