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...
Revision u/s 263 - The Tribunal concluded that the assessing officer had conducted a reasonable inquiry into the relevant issues, and the assessment order was neither erroneous nor prejudicial to the interests of the Revenue. Despite the discrepancy between the intended scrutiny and the actual assessment, the Tribunal upheld the validity of the assessment order. Additionally, the Tribunal rejected the application of Instruction No. 9/2007, stating its inapplicability to the case at hand. - In light of the findings, the High Court dismissed the appeal, as it found no question of law arising from the impugned order.
Revision u/s 263 - The Tribunal concluded that the assessing officer had conducted a reasonable inquiry into the relevant issues, and the assessment order was neither erroneous nor prejudicial to the interests of the Revenue. Despite the discrepancy between the intended scrutiny and the actual assessment, the Tribunal upheld the validity of the assessment order. Additionally, the Tribunal rejected the application of Instruction No. 9/2007, stating its inapplicability to the case at hand. - In light of the findings, the High Court dismissed the appeal, as it found no question of law arising from the impugned order.
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