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...
AO exceeded jurisdiction by disallowing claim of brought forward unabsorbed depreciation through rectification u/s 154, as CIT(A) did not direct such disallowance. CIT(A) order attained finality on this issue. Post CIT(A) order, AO cannot rectify u/s 154 in absence of mistake apparent from record. CIT(A) order upheld, Revenue's appeal dismissed.
AO exceeded jurisdiction by disallowing claim of brought forward unabsorbed depreciation through rectification u/s 154, as CIT(A) did not direct such disallowance. CIT(A) order attained finality on this issue. Post CIT(A) order, AO cannot rectify u/s 154 in absence of mistake apparent from record. CIT(A) order upheld, Revenue's appeal dismissed.
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