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 - period of limitation - It is indisputable that the limitation period for assessment warrants strict interpretation; however, the facts presented to us confirm conclusively that the search concluded on 29th April, 2021. Therefore, it is implausible to assert that the assessment order of 31st March, 2023 notified under Section 153A of IT Act exceeds the twelve-month limitation period. - HC
Revision u/s 263 - period of limitation - It is indisputable that the limitation period for assessment warrants strict interpretation; however, the facts presented to us confirm conclusively that the search concluded on 29th April, 2021. Therefore, it is implausible to assert that the assessment order of 31st March, 2023 notified under Section 153A of IT Act exceeds the twelve-month limitation period. - HC
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