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 order u/s 148A(d) - An order under Section 148 (d) of the Income Tax Act, 1961, itself is neither an assessment nor a demand and petitioner still will have ample scope and opportunity to make out a case if any for dropping of the proceeding under Section 147 of the Act in subsequent proceeding after the order passed under Section 148 (d) of the Act. WP dismissed. - HC
Validity of order u/s 148A(d) - An order under Section 148 (d) of the Income Tax Act, 1961, itself is neither an assessment nor a demand and petitioner still will have ample scope and opportunity to make out a case if any for dropping of the proceeding under Section 147 of the Act in subsequent proceeding after the order passed under Section 148 (d) of the Act. WP dismissed. - HC
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