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...
Settlement of a Case - Procedure u/s 245D - Non deposit of admitted tax u/s 245C on time - Payment of the taxes of additional income partly by way of adjustment against cash seized. - On receiving notice, petitioner paid the amount through challan and placed the same on file - The confusion and the error, if at all, arises only from the contents of letter dated 17.12.2018. The unambiguous impression that it conveys is that the entirety of the credit determined as balance in the PD account enured to the benefit of this petitioner. - Settlement application stands restored - HC
Settlement of a Case - Procedure u/s 245D - Non deposit of admitted tax u/s 245C on time - Payment of the taxes of additional income partly by way of adjustment against cash seized. - On receiving notice, petitioner paid the amount through challan and placed the same on file - The confusion and the error, if at all, arises only from the contents of letter dated 17.12.2018. The unambiguous impression that it conveys is that the entirety of the credit determined as balance in the PD account enured to the benefit of this petitioner. - Settlement application stands restored - HC
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