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 Reassessment proceedings - reason to believe escapement of income - The High Court agreed with the petitioner's contention that the reasons provided by the Assessing Officer indicated a clear case of change of opinion. The expenses in question had been considered and allowed during the assessment proceedings, and reopening the assessment based on the same grounds was unjustified.
Validity of Reassessment proceedings - reason to believe escapement of income - The High Court agreed with the petitioner's contention that the reasons provided by the Assessing Officer indicated a clear case of change of opinion. The expenses in question had been considered and allowed during the assessment proceedings, and reopening the assessment based on the same grounds was unjustified.
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