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 - corrigendum issued to make changes in reaosns to belive - the action of the AO to be wholly untenable in law. By issue of corrigendum, the Assessing Officer has attempted to rectify the very fulcrum of believe derived qua the broker - The name of the broker was substituted in the corrigendum which has changed the tone of the entire basis for assumption of jurisdiction u/s 147 - AT
Reopening of assessment u/s 147 - corrigendum issued to make changes in reaosns to belive - the action of the AO to be wholly untenable in law. By issue of corrigendum, the Assessing Officer has attempted to rectify the very fulcrum of believe derived qua the broker - The name of the broker was substituted in the corrigendum which has changed the tone of the entire basis for assumption of jurisdiction u/s 147 - AT
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