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 reopening of assessment - period of limitation for issuance of notice u/s 148 - It is not the actual communication of the notice that is relevant. It is the issuance of the notice. - Scope of new regime u/s 148A - Once the notice has been dispatched either electronically or through post on the last date prescribed u/s 149 the proceeding cannot be questioned as time barred. - HC
Validity of reopening of assessment - period of limitation for issuance of notice u/s 148 - It is not the actual communication of the notice that is relevant. It is the issuance of the notice. - Scope of new regime u/s 148A - Once the notice has been dispatched either electronically or through post on the last date prescribed u/s 149 the proceeding cannot be questioned as time barred. - HC
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