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 - large share premium received - valuation of shares and the applicability of Section 56(2)(viib) - The Tribunal found that the PCIT's order was erroneous as it did not properly consider the assessee's provided documentation and valuation report under Rule 11UA of the Income Tax Rules. The Tribunal concluded that the original assessment order by the Assessing Officer (AO) was not erroneous, and thus, the exercise of power u/s 263 by the PCIT was incorrect.
Revision u/s 263 - large share premium received - valuation of shares and the applicability of Section 56(2)(viib) - The Tribunal found that the PCIT's order was erroneous as it did not properly consider the assessee's provided documentation and valuation report under Rule 11UA of the Income Tax Rules. The Tribunal concluded that the original assessment order by the Assessing Officer (AO) was not erroneous, and thus, the exercise of power u/s 263 by the PCIT was incorrect.
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