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...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Validity of faceless assessment challenged due to non-compliance with Section 151A - notices issued by Joint Assessing Officer (JAO) instead of Faceless Assessing Officer (FAO). High Court held that JAO lacked jurisdiction to issue notices u/s 148, particularly in view of Section 151A read with Central Government notification dated 29 March 2022. Relying on Hexaware Technologies Ltd. case, the Court ruled the impugned notices illegal and invalid as JAO had no jurisdiction. Petition allowed in favor of assessee.
Validity of faceless assessment challenged due to non-compliance with Section 151A - notices issued by Joint Assessing Officer (JAO) instead of Faceless Assessing Officer (FAO). High Court held that JAO lacked jurisdiction to issue notices u/s 148, particularly in view of Section 151A read with Central Government notification dated 29 March 2022. Relying on Hexaware Technologies Ltd. case, the Court ruled the impugned notices illegal and invalid as JAO had no jurisdiction. Petition allowed in favor of assessee.
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