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 - genuineness of transactions of purchase of gold bars - transactions with person who is engaged in providing accommodative entries - There is nothing to say why Petitioner’s explanation cannot be accepted. We are also surprised that to issue such an order the PCIT even gave sanction which also reflects total non-application of mind by the PCIT. - matter restored back with directions - HC
Reopening of assessment u/s 147 - genuineness of transactions of purchase of gold bars - transactions with person who is engaged in providing accommodative entries - There is nothing to say why Petitioner’s explanation cannot be accepted. We are also surprised that to issue such an order the PCIT even gave sanction which also reflects total non-application of mind by the PCIT. - matter restored back with directions - HC
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