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...
Reassessment proceedings barred by limitation period u/s 149(1)(b) of Finance Act, 2021. Impugned notice u/s 148 dated 15.04.2021 for AY 2015-16 quashed. Consequential reassessment proceedings set aside due to lack of sanction/approval for issuance of notice as per substituted Finance Act, 2021. Appellant succeeds on legal issues, decided in favor of assessee.
Reassessment proceedings barred by limitation period u/s 149(1)(b) of Finance Act, 2021. Impugned notice u/s 148 dated 15.04.2021 for AY 2015-16 quashed. Consequential reassessment proceedings set aside due to lack of sanction/approval for issuance of notice as per substituted Finance Act, 2021. Appellant succeeds on legal issues, decided in favor of assessee.
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