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...
Reopening of assessment u/s 147 - addition u/s 68 - information received from Investigation Wing, Kolkata that the assessee is a beneficiary of circuitous transaction of cash deposits through various layers and bank accounts - it is also well settled that the sufficiency or correctness of the material is not a thing to be considered at the stage of recording the reasons. - Re-assessment proceedings sustained - However, on merits the additions made u/s 68 stands deleted - AT
Reopening of assessment u/s 147 - addition u/s 68 - information received from Investigation Wing, Kolkata that the assessee is a beneficiary of circuitous transaction of cash deposits through various layers and bank accounts - it is also well settled that the sufficiency or correctness of the material is not a thing to be considered at the stage of recording the reasons. - Re-assessment proceedings sustained - However, on merits the additions made u/s 68 stands deleted - AT
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