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...
Validity of reopening of assessment - This Court is of the view that if the allegations in the order passed under Section 148A(d) of the Act are correct, then the Petitioner’s defence that the transaction had already been subjected to tax is not correct inasmuch as the sale would be treated as unexplained cash credit under Section 68 of the Act and the full value would be liable to tax. - HC
Validity of reopening of assessment - This Court is of the view that if the allegations in the order passed under Section 148A(d) of the Act are correct, then the Petitioner’s defence that the transaction had already been subjected to tax is not correct inasmuch as the sale would be treated as unexplained cash credit under Section 68 of the Act and the full value would be liable to tax. - HC
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