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...
The ITAT Gauhati Bench jurisdiction issue was raised concerning an appeal filed under improper jurisdiction. The assessee's address was consistently in Kolkata, with no formal transfer to Gauhati jurisdiction. Referring to legal precedents, the appeal was deemed under improper jurisdiction due to the assessment order's origin in Kolkata. The appeal was dismissed, allowing the Revenue to refile before the appropriate ITAT bench with a delay condonation petition. The time taken for the dismissed appeal may be considered for delay condonation in the refiled appeal.
The ITAT Gauhati Bench jurisdiction issue was raised concerning an appeal filed under improper jurisdiction. The assessee's address was consistently in Kolkata, with no formal transfer to Gauhati jurisdiction. Referring to legal precedents, the appeal was deemed under improper jurisdiction due to the assessment order's origin in Kolkata. The appeal was dismissed, allowing the Revenue to refile before the appropriate ITAT bench with a delay condonation petition. The time taken for the dismissed appeal may be considered for delay condonation in the refiled appeal.
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