Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Validity of reopening of assessment - notice u/s 148 against petitioner company after the approval of the resolution plan for a period prior to closing - liability of previous management - Citing legal precedents and provisions of the Insolvency and Bankruptcy Code, the High court concluded that once a resolution plan is approved, all dues including statutory dues stand extinguished, and proceedings in respect of such dues cannot be continued. - The court clarified that Section 148 of the Income-tax Act pertains to the assessment of escaped income and cannot be used for purposes beyond its scope, such as collecting evidence against third parties.
Validity of reopening of assessment - notice u/s 148 against petitioner company after the approval of the resolution plan for a period prior to closing - liability of previous management - Citing legal precedents and provisions of the Insolvency and Bankruptcy Code, the High court concluded that once a resolution plan is approved, all dues including statutory dues stand extinguished, and proceedings in respect of such dues cannot be continued. - The court clarified that Section 148 of the Income-tax Act pertains to the assessment of escaped income and cannot be used for purposes beyond its scope, such as collecting evidence against third parties.
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