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 Faceless assessments framed u/s 144B - Though failure to issue the notices as provided in Section 144B would certainly vitiate the proceedings as being in violation of the principles of natural justice, it is an infirmity that may be cured by permitting such SCN/DAO to be issued now. The impugned assessments are set aside and liberty granted to the respondents to complete the assessments de novo, in accordance with law. - HC
Validity of Faceless assessments framed u/s 144B - Though failure to issue the notices as provided in Section 144B would certainly vitiate the proceedings as being in violation of the principles of natural justice, it is an infirmity that may be cured by permitting such SCN/DAO to be issued now. The impugned assessments are set aside and liberty granted to the respondents to complete the assessments de novo, in accordance with law. - HC
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