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...
Rectification u/s 154 - disallowance of carrying forward of the loss - The High Court examined the contentions of both parties and found merit in the petitioner's argument regarding the violation of Section 154(3) of the Act. It emphasized that any rectification adversely affecting the assessee's interests must be preceded by a notice and an opportunity to be heard. Since such compliance was lacking in the impugned order, the Court deemed it unsustainable and set it aside.
Rectification u/s 154 - disallowance of carrying forward of the loss - The High Court examined the contentions of both parties and found merit in the petitioner's argument regarding the violation of Section 154(3) of the Act. It emphasized that any rectification adversely affecting the assessee's interests must be preceded by a notice and an opportunity to be heard. Since such compliance was lacking in the impugned order, the Court deemed it unsustainable and set it aside.
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