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...
Assessment to be framed u/s 153C OR u/s 147/148 - Validity of the reassessment proceedings - Initiation of action u/s 153C would arise only if the seized material are handed over to the AO of such other person having jurisdiction of such other person - It is no so in the present case - no fault in the initiation of proceedings u/s 147/148 - AT
Assessment to be framed u/s 153C OR u/s 147/148 - Validity of the reassessment proceedings - Initiation of action u/s 153C would arise only if the seized material are handed over to the AO of such other person having jurisdiction of such other person - It is no so in the present case - no fault in the initiation of proceedings u/s 147/148 - AT
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