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 assessment passed u/s 153A pursuant to search and seizure - The High Court has observed and held that, the assessee’s assessment for the relevant year stood completed as on 06.06.2003 long before the search and consequent proceeding initiated u/s 153A and there is no question arising of the relevant assessment to abate under the second proviso to Section 153A. - Tribunal was perfectly within the statutory framework, in making a remand directing the AO to carry out re-assessment of the assessment year 2002-03, which stood completed as on the date of initiation of Section 153A proceedings, if some incriminating material seized during the search is available.
Validity of assessment passed u/s 153A pursuant to search and seizure - The High Court has observed and held that, the assessee’s assessment for the relevant year stood completed as on 06.06.2003 long before the search and consequent proceeding initiated u/s 153A and there is no question arising of the relevant assessment to abate under the second proviso to Section 153A. - Tribunal was perfectly within the statutory framework, in making a remand directing the AO to carry out re-assessment of the assessment year 2002-03, which stood completed as on the date of initiation of Section 153A proceedings, if some incriminating material seized during the search is available.
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