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...
Exemption u/s 11 - Reopening of assessment u/s 147 - whether jurisdiction was vested on the ld. CIT(E) and not with the Territorial Commissioner? - the registration U/s 12AA is in action from the year of application. So, the year of application is considered as deemed registration and the claim of deduction u/s 11 and 12 should be applicable accordingly. Accordingly, the assessing authority had acted beyond jurisdiction. - AT
Exemption u/s 11 - Reopening of assessment u/s 147 - whether jurisdiction was vested on the ld. CIT(E) and not with the Territorial Commissioner? - the registration U/s 12AA is in action from the year of application. So, the year of application is considered as deemed registration and the claim of deduction u/s 11 and 12 should be applicable accordingly. Accordingly, the assessing authority had acted beyond jurisdiction. - AT
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