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 - valid approval u/s 151 - “unsigned approval” issued in electronic form - The point of time when the AO issued notices u/s 148, he was having no jurisdiction to issue the impugned notices under section 148 of the Act, 1961. Consequently the impugned notices issued by the AO u/s 148 were without jurisdiction. The questions no. (a) and (b) are answered accordingly. - HC
Reopening of assessment u/s 147 - valid approval u/s 151 - “unsigned approval” issued in electronic form - The point of time when the AO issued notices u/s 148, he was having no jurisdiction to issue the impugned notices under section 148 of the Act, 1961. Consequently the impugned notices issued by the AO u/s 148 were without jurisdiction. The questions no. (a) and (b) are answered accordingly. - HC
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