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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Reopening of assessment u/s 147 - failure to provide the copy of recording of "reason to believe" to the assessee - copy of reasons recorded has to be provided to assessee before completion of assessment order. We find that CIT(A) has rightly accepted the contention of the assessee and after relying on number of case laws, decided the issue in favour of the assessee. - AT
Reopening of assessment u/s 147 - failure to provide the copy of recording of "reason to believe" to the assessee - copy of reasons recorded has to be provided to assessee before completion of assessment order. We find that CIT(A) has rightly accepted the contention of the assessee and after relying on number of case laws, decided the issue in favour of the assessee. - AT
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