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 u/s 147 - reasons to believe - The Tribunal held that the reasons for reopening the assessment were vague and non-specific, and there was no failure on the part of the Assessee to fully disclose all material facts during the original assessment proceedings. Therefore, the initiation of reassessment proceedings was struck down.
Reopening of assessment u/s 147 - reasons to believe - The Tribunal held that the reasons for reopening the assessment were vague and non-specific, and there was no failure on the part of the Assessee to fully disclose all material facts during the original assessment proceedings. Therefore, the initiation of reassessment proceedings was struck down.
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