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...
Determining the jurisdiction of appellate forum - jurisdiction of this Tribunal - The Tribunal refers to the legal precedent established in a Supreme Court case regarding the jurisdiction of appellate forums, emphasizing that the "situs of the assessing officer" is the determining factor regardless of administrative orders. Since the location of the Assessing Officer falls outside the Tribunal's territorial jurisdiction, the appeal is deemed not maintainable. Therefore, the Tribunal dismisses both the Revenue's appeal and the assessee's cross objection, granting them the option to file before the appropriate bench with jurisdiction over the Assessing Officer's location.
Determining the jurisdiction of appellate forum - jurisdiction of this Tribunal - The Tribunal refers to the legal precedent established in a Supreme Court case regarding the jurisdiction of appellate forums, emphasizing that the "situs of the assessing officer" is the determining factor regardless of administrative orders. Since the location of the Assessing Officer falls outside the Tribunal's territorial jurisdiction, the appeal is deemed not maintainable. Therefore, the Tribunal dismisses both the Revenue's appeal and the assessee's cross objection, granting them the option to file before the appropriate bench with jurisdiction over the Assessing Officer's location.
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