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...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
The period in question is beyond the period of five years. It is a settled position that no demand can be raised beyond the period of five years. The assessee is correct in saying that the show cause notice is barred by time and is unsustainable. - AT
The period in question is beyond the period of five years. It is a settled position that no demand can be raised beyond the period of five years. The assessee is correct in saying that the show cause notice is barred by time and is unsustainable. - AT
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