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...
Rectification u/s 154 - Addition u/s. 69 - Power of AO u/s 116 - Nothing is discernible therefrom, which jeopardizes the power of the A.O. in rectifying mistakes apparent from the record after seeking any instruction/guidance from a superior authority. As the contention of the Ld. AR is devoid and bereft of any force of law; therefore, the same is dismissed. - AT
Rectification u/s 154 - Addition u/s. 69 - Power of AO u/s 116 - Nothing is discernible therefrom, which jeopardizes the power of the A.O. in rectifying mistakes apparent from the record after seeking any instruction/guidance from a superior authority. As the contention of the Ld. AR is devoid and bereft of any force of law; therefore, the same is dismissed. - AT
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