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...
Reopening of assessment u/s 147 - Validity of order 148A - the reassessment proceedings initiated are unsustainable on the the ground of violation of the procedure prescribed u/s 148A(b) of the Act on account of failure of the AO to provide the requisite material which ought to have been supplied alongwith the information in terms of the said section. - The order impugned passed u/s 148A(d), the notice impugned u/s 148 of the Act are hereby quashed. - HC
Reopening of assessment u/s 147 - Validity of order 148A - the reassessment proceedings initiated are unsustainable on the the ground of violation of the procedure prescribed u/s 148A(b) of the Act on account of failure of the AO to provide the requisite material which ought to have been supplied alongwith the information in terms of the said section. - The order impugned passed u/s 148A(d), the notice impugned u/s 148 of the Act are hereby quashed. - HC
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