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 - Reason to believe - The notice was based on alleged undisclosed cash deposits made by the trust during a specific financial year. The trust objected to the reopening, arguing that all income was duly recorded and offered for taxation. The High court found that the reasons provided for reopening were unsubstantiated and lacked a rational connection to establish income escapement. It emphasized the impermissibility of fishing expeditions without concrete evidence. Consequently, the court set aside the notice of reopening.
Reopening of assessment u/s 147 - Reason to believe - The notice was based on alleged undisclosed cash deposits made by the trust during a specific financial year. The trust objected to the reopening, arguing that all income was duly recorded and offered for taxation. The High court found that the reasons provided for reopening were unsubstantiated and lacked a rational connection to establish income escapement. It emphasized the impermissibility of fishing expeditions without concrete evidence. Consequently, the court set aside the notice of reopening.
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