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 - Reasons to believe - AO was not having any reason to believe for initiating re-assessment - There cannot be any re-assessment for a reason to suspect and re-assessment is only to be done if the AO has reasons to believe that the Assessee has escaped assessment - HC
Reopening of assessment u/s 147 - Reasons to believe - AO was not having any reason to believe for initiating re-assessment - There cannot be any re-assessment for a reason to suspect and re-assessment is only to be done if the AO has reasons to believe that the Assessee has escaped assessment - HC
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