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...
Transfer of Jurisdiction u/s 127 - File were transferred from Kolkata's jurisdiction to Chennai - The Revenue's argument that the PAN and files were still within Kolkata's jurisdiction was dismissed, as the transfer of jurisdiction was a consequential proceeding. The Tribunal's decision was upheld, and the appeal failed against the Revenue.
Transfer of Jurisdiction u/s 127 - File were transferred from Kolkata's jurisdiction to Chennai - The Revenue's argument that the PAN and files were still within Kolkata's jurisdiction was dismissed, as the transfer of jurisdiction was a consequential proceeding. The Tribunal's decision was upheld, and the appeal failed against the Revenue.
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