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...
Revision u/s 263 by CIT - The same issue was again sought to be inquired into by the PCIT/CIT/ revisional authority which could not be allowed to be inquired multiple times. The order passed by the AO as such could not be stated to be erroneous and since as per the re-assessment, no income was held to have escaped assessment by the AO and as PCIT/CIT also could not bring any such material on record, therefore, the assessment order cannot be held to be pre-judicial to the interest of revenue - HC
Revision u/s 263 by CIT - The same issue was again sought to be inquired into by the PCIT/CIT/ revisional authority which could not be allowed to be inquired multiple times. The order passed by the AO as such could not be stated to be erroneous and since as per the re-assessment, no income was held to have escaped assessment by the AO and as PCIT/CIT also could not bring any such material on record, therefore, the assessment order cannot be held to be pre-judicial to the interest of revenue - HC
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