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...
Reopening of assessment u/s 147 - Lack of full disclosures - Time given vide SCN dated 13.09.2021 is too short - To be noted, vide paragraph 3 of the SCN, writ petitioner-assessee was called upon to respond by 23:59 hours on 16.09.2021. 13.09.2021 is a Monday and obviously 16.09.2021 is Wednesday and that fairly three working days. It is clearly insufficient. - the impugned assessment order made by the first respondent is set aside on the grounds of lack of opportunity / specificity - Matter restored back - HC
Reopening of assessment u/s 147 - Lack of full disclosures - Time given vide SCN dated 13.09.2021 is too short - To be noted, vide paragraph 3 of the SCN, writ petitioner-assessee was called upon to respond by 23:59 hours on 16.09.2021. 13.09.2021 is a Monday and obviously 16.09.2021 is Wednesday and that fairly three working days. It is clearly insufficient. - the impugned assessment order made by the first respondent is set aside on the grounds of lack of opportunity / specificity - Matter restored back - HC
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