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...
Validity of reopening of assessment u/s 147 - shorter period to reply to notice - The High Court acknowledged the petitioner's argument regarding the limited time provided for response. Considering the petitioner's status as a Public Trust running a school, the Court deemed it appropriate to grant an opportunity for a reply to the notice. - The Court, without expressing an opinion on the merits, quashed the impugned order and remanded the matter for fresh consideration.
Validity of reopening of assessment u/s 147 - shorter period to reply to notice - The High Court acknowledged the petitioner's argument regarding the limited time provided for response. Considering the petitioner's status as a Public Trust running a school, the Court deemed it appropriate to grant an opportunity for a reply to the notice. - The Court, without expressing an opinion on the merits, quashed the impugned order and remanded the matter for fresh consideration.
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