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 passed u/s 147 - not providing any opportunity of hearing - Though this Court is very reluctant to interfere with any order u/s 143(3) or u/s 147 since the same is an appealable order but in this case admittedly the respondent Income Tax Authority has acted contrary to and in noncompliance of statutory provision of law and in view of this admitted legal and factual position, the aforesaid impugned order passed u/s 147 is set aside - HC
Validity of order passed u/s 147 - not providing any opportunity of hearing - Though this Court is very reluctant to interfere with any order u/s 143(3) or u/s 147 since the same is an appealable order but in this case admittedly the respondent Income Tax Authority has acted contrary to and in noncompliance of statutory provision of law and in view of this admitted legal and factual position, the aforesaid impugned order passed u/s 147 is set aside - HC
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