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...
Validity of reopening of assessment u/s 147 - Reason to believe - The court scrutinized the purported tangible material for reopening, which consisted of audit objections received after the original assessment. However, it noted that the objections had been duly explained by the petitioner during the original assessment proceedings, and the assessing officer had found the explanations satisfactory. Therefore, the court concluded that there was no fresh tangible material justifying the reopening of the assessment.
Validity of reopening of assessment u/s 147 - Reason to believe - The court scrutinized the purported tangible material for reopening, which consisted of audit objections received after the original assessment. However, it noted that the objections had been duly explained by the petitioner during the original assessment proceedings, and the assessing officer had found the explanations satisfactory. Therefore, the court concluded that there was no fresh tangible material justifying the reopening of the assessment.
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