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 - Validity of grant the approval by the PCIT - relevancy of information reported by Insight portal - Despite the petitioner's explanations and evidence of proper accounting, the Assessing Officer issued an impugned order claiming significant income escapement. However, the Court found discrepancies between the notice and the order, highlighting the AO's limited authority to reassess income based solely on the issues raised in the notice. Ultimately, the Court allowed the petition, quashing both the impugned order and notice.
Validity of reopening of assessment - Validity of grant the approval by the PCIT - relevancy of information reported by Insight portal - Despite the petitioner's explanations and evidence of proper accounting, the Assessing Officer issued an impugned order claiming significant income escapement. However, the Court found discrepancies between the notice and the order, highlighting the AO's limited authority to reassess income based solely on the issues raised in the notice. Ultimately, the Court allowed the petition, quashing both the impugned order and notice.
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