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...
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Validity of order of ITAT allowing Applications filed u/s 254(2) - Rectification versus Review of order - TP Adjustment - The High court observed that the ITAT had rendered incompatible and inconsistent findings in its original order. - The court noted a contradiction between paragraphs 12 and 21 of the original order. - It was deemed necessary for the ITAT to recall its previous order and correct the error to avoid leaving the TPO and Assessing Officer in a quandary. - The court found that the issue of comparability regarding one company was left open for the ITAT's consideration, while another company's matter was remitted to the TPO. - Ultimately, the court determined that the appeal of Revenue did not raise any substantial question of law and dismissed it accordingly.
Validity of order of ITAT allowing Applications filed u/s 254(2) - Rectification versus Review of order - TP Adjustment - The High court observed that the ITAT had rendered incompatible and inconsistent findings in its original order. - The court noted a contradiction between paragraphs 12 and 21 of the original order. - It was deemed necessary for the ITAT to recall its previous order and correct the error to avoid leaving the TPO and Assessing Officer in a quandary. - The court found that the issue of comparability regarding one company was left open for the ITAT's consideration, while another company's matter was remitted to the TPO. - Ultimately, the court determined that the appeal of Revenue did not raise any substantial question of law and dismissed it accordingly.
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