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 court examined the reasons recorded for re-assessment provided to the petitioner and compared them with the proforma maintained by the respondent. It noted minor differences in language but found that the substance of the reasons remained consistent. The court emphasized that the material basis for initiating re-assessment was the same in both documents, and minor variations in language did not warrant interference with the proceedings. - The writ petition was dismissed, upholding the validity of the notices issued for re-assessment.
Reopening of assessment u/s 147 - Reasons to believe - The court examined the reasons recorded for re-assessment provided to the petitioner and compared them with the proforma maintained by the respondent. It noted minor differences in language but found that the substance of the reasons remained consistent. The court emphasized that the material basis for initiating re-assessment was the same in both documents, and minor variations in language did not warrant interference with the proceedings. - The writ petition was dismissed, upholding the validity of the notices issued for re-assessment.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
