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...
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The Appellate Tribunal concurred with the Mumbai Tribunal's order in M/s Pooja Marketing, which comprehensively dealt with all aspects, facts, and applicable case laws. The bench not only considered the validity of revisionary jurisdiction u/s 263 but also decided the issue on merits in favor of the assessee. The case law in CIT vs. Dr. M.A.M. Ramaswamy was distinguished by the learned Senior Counsel in written submissions, which was deliberated upon and found concurrence. No distinguishing feature or reversal of the Mumbai Tribunal's decision by higher judicial authorities was shown. The Tribunal dismissed the revenue's appeal after elaborately dealing with the issue on merits.
The Appellate Tribunal concurred with the Mumbai Tribunal's order in M/s Pooja Marketing, which comprehensively dealt with all aspects, facts, and applicable case laws. The bench not only considered the validity of revisionary jurisdiction u/s 263 but also decided the issue on merits in favor of the assessee. The case law in CIT vs. Dr. M.A.M. Ramaswamy was distinguished by the learned Senior Counsel in written submissions, which was deliberated upon and found concurrence. No distinguishing feature or reversal of the Mumbai Tribunal's decision by higher judicial authorities was shown. The Tribunal dismissed the revenue's appeal after elaborately dealing with the issue on merits.
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