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 reopening of assessment - doctrine of merger - The ITAT unequivocally quashed the reassessment proceedings initiated against the appellant for the Assessment Year 2006-07, ruling them as bad-in-law due to the procedural flaw of issuing a notice under section 147 beyond the four-year period without specifying the particulars of omitted income - The judgment also indirectly supports the appellant's contention regarding the classification of certain incomes as business incomes eligible for section 80IA deductions, though this specific issue became moot following the quashing of the reassessment order.
Validity of reopening of assessment - doctrine of merger - The ITAT unequivocally quashed the reassessment proceedings initiated against the appellant for the Assessment Year 2006-07, ruling them as bad-in-law due to the procedural flaw of issuing a notice under section 147 beyond the four-year period without specifying the particulars of omitted income - The judgment also indirectly supports the appellant's contention regarding the classification of certain incomes as business incomes eligible for section 80IA deductions, though this specific issue became moot following the quashing of the reassessment order.
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