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...
Revisional jurisdiction u/s 264 - Application u/s 264 rejected as intimation u/s 143(1) of the Act is not an order amenable to revisional jurisdiction u/s 264 - The court ruled that intimation under Section 143(1) is amenable to revisional jurisdiction under Section 264 of the Act. This was based on precedent in "Diwaker Tripathi v. Principal Commissioner of Income tax – 17 & Ors.", which allowed for such revision.
Revisional jurisdiction u/s 264 - Application u/s 264 rejected as intimation u/s 143(1) of the Act is not an order amenable to revisional jurisdiction u/s 264 - The court ruled that intimation under Section 143(1) is amenable to revisional jurisdiction under Section 264 of the Act. This was based on precedent in "Diwaker Tripathi v. Principal Commissioner of Income tax – 17 & Ors.", which allowed for such revision.
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