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 assessment order - non-speaking assessment order - non-application of mind - violation of principles of natural justice - reversal of ITC - The petitioner contended that the order failed to consider their submissions adequately. The High Court found merit in the petitioner's arguments, noting instances where the assessing officer failed to provide proper reasoning and overlooked relevant material. As a result, the Court quashed the order and directed a fresh assessment
Validity of assessment order - non-speaking assessment order - non-application of mind - violation of principles of natural justice - reversal of ITC - The petitioner contended that the order failed to consider their submissions adequately. The High Court found merit in the petitioner's arguments, noting instances where the assessing officer failed to provide proper reasoning and overlooked relevant material. As a result, the Court quashed the order and directed a fresh assessment
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