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 - prior period of expenses - mercantile system of accounting - The petitioner argued that the reliance on the assessment order for AY 2010-2011 was unjustified since the Commissioner of Income Tax (Appeals) [CIT(A)] later allowed the prior period expenses for that year, and the Revenue accepted the CIT(A)'s order. The Income Tax Appellate Tribunal (ITAT) also upheld this position in a similar case. - The High court agreed with the petitioner and quashed the reassessment proceedings.
Reopening of assessment - prior period of expenses - mercantile system of accounting - The petitioner argued that the reliance on the assessment order for AY 2010-2011 was unjustified since the Commissioner of Income Tax (Appeals) [CIT(A)] later allowed the prior period expenses for that year, and the Revenue accepted the CIT(A)'s order. The Income Tax Appellate Tribunal (ITAT) also upheld this position in a similar case. - The High court agreed with the petitioner and quashed the reassessment proceedings.
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