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...
Validity of reassessment proceedings - non-affording the petitioner an opportunity of being heard as mandated u/s 148A(b) - The court dismissed the Revenue's appeal, affirming the judgment of the learned Single Judge. It held that the requirement of providing an opportunity of being heard includes the right to a personal hearing, as mandated by Section 148A of the Income Tax Act. - The HC has also taken note of the amendment to the provisions of Section 148A(b) through the Finance Act, 2022 with effect from 1.4.2022.
Validity of reassessment proceedings - non-affording the petitioner an opportunity of being heard as mandated u/s 148A(b) - The court dismissed the Revenue's appeal, affirming the judgment of the learned Single Judge. It held that the requirement of providing an opportunity of being heard includes the right to a personal hearing, as mandated by Section 148A of the Income Tax Act. - The HC has also taken note of the amendment to the provisions of Section 148A(b) through the Finance Act, 2022 with effect from 1.4.2022.
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