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 High Court held that the reopening of the assessment based on a subsequent judgment that the transaction in question was amenable to tax was impermissible. Once an assessment has become final, it cannot be reopened on the basis of a subsequent judgment of the Supreme Court. The department cannot reopen an assessment that stood closed based on the law prevailing at the relevant time. The reassessment initiated on the basis of a subsequent judgment was rendered a colourable exercise of power and without jurisdiction.
The High Court held that the reopening of the assessment based on a subsequent judgment that the transaction in question was amenable to tax was impermissible. Once an assessment has become final, it cannot be reopened on the basis of a subsequent judgment of the Supreme Court. The department cannot reopen an assessment that stood closed based on the law prevailing at the relevant time. The reassessment initiated on the basis of a subsequent judgment was rendered a colourable exercise of power and without jurisdiction.
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