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...
Set off and withholding of refunds u/s 245 - Adjustment of refund amount with the demand of tax for the subsequent years - petitioner has agreed that, against the refund due qua AY 2021-2022 & 2022-23, adjustment is made to the extent of 20% of the demand raised for AY 2017-18. - directions issued for refund of the balance amount accordingly - HC
Set off and withholding of refunds u/s 245 - Adjustment of refund amount with the demand of tax for the subsequent years - petitioner has agreed that, against the refund due qua AY 2021-2022 & 2022-23, adjustment is made to the extent of 20% of the demand raised for AY 2017-18. - directions issued for refund of the balance amount accordingly - HC
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