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 - The High court observed that the reasons for reopening did not specifically allege any failure on the part of the petitioner to disclose all material facts. Moreover, the issues raised were already considered during the original assessment proceedings. Therefore, the reopening based on a change of opinion was not justified.
Validity of reopening of assessment - The High court observed that the reasons for reopening did not specifically allege any failure on the part of the petitioner to disclose all material facts. Moreover, the issues raised were already considered during the original assessment proceedings. Therefore, the reopening based on a change of opinion was not justified.
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