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...
Validity of reopening of assessment u/s 147 r.w.s. 148A(b) - Petitioner claimed that despite certain transactions being booked under the PAN of erstwhile company (amalgamated company) due to an error, they had correctly considered all transactions in their return. - The court found merit in the petitioner's contention regarding the lack of proper application of mind in granting approval under Section 151. They observed discrepancies in the approval process, indicating a failure to review the request and draft order adequately. Consequently, the court deemed it appropriate to quash the order under Section 148A(d) of the Act and the consequent notice issued under Section 148.
Validity of reopening of assessment u/s 147 r.w.s. 148A(b) - Petitioner claimed that despite certain transactions being booked under the PAN of erstwhile company (amalgamated company) due to an error, they had correctly considered all transactions in their return. - The court found merit in the petitioner's contention regarding the lack of proper application of mind in granting approval under Section 151. They observed discrepancies in the approval process, indicating a failure to review the request and draft order adequately. Consequently, the court deemed it appropriate to quash the order under Section 148A(d) of the Act and the consequent notice issued under Section 148.
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