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...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Provisions relating to reassessment proceedings - It has been proposed that the section 148 of the Act may be amended to provide that a return in response to a notice u/s 148 of the Act shall be furnished within three months from the end of the month in which such notice is issued, or within such further time as may be allowed by the AO on a request made in this behalf by the assessee. However, any return which is furnished beyond the period allowed in the section 148 to furnish such return of income shall not be deemed to be a return u/s 139 of the Act. As a result, the consequential requirements viz. notice under section 143(2) etc. would not be mandatory for such returns.
Provisions relating to reassessment proceedings - It has been proposed that the section 148 of the Act may be amended to provide that a return in response to a notice u/s 148 of the Act shall be furnished within three months from the end of the month in which such notice is issued, or within such further time as may be allowed by the AO on a request made in this behalf by the assessee. However, any return which is furnished beyond the period allowed in the section 148 to furnish such return of income shall not be deemed to be a return u/s 139 of the Act. As a result, the consequential requirements viz. notice under section 143(2) etc. would not be mandatory for such returns.
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