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 assessment - shorter time period to respond - It is clear that the Impugned Order has been passed to ensure that the assessment does not get barred by limitation u/s 153 of the Income Tax Act, 1961. The procedure u/s 144B, as in force between 01.04.2021 till 30.03.2022 was required to be followed. It has not been fully followed. - Matter restored back - HC
Validity of assessment - shorter time period to respond - It is clear that the Impugned Order has been passed to ensure that the assessment does not get barred by limitation u/s 153 of the Income Tax Act, 1961. The procedure u/s 144B, as in force between 01.04.2021 till 30.03.2022 was required to be followed. It has not been fully followed. - Matter restored back - HC
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