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...
Assessment/reassessment proceedings against an insolvent company were quashed. A resolution plan was approved by the Tribunal u/s 30(6) of the Insolvency and Bankruptcy Code. The claim lodged by the Deputy Commissioner of Income Tax was verified and admitted during the NCLT proceedings. As per the Code's provisions, no person can initiate or continue proceedings regarding claims for dues relating to the period prior to the resolution plan's approval. Consequently, the Assessment Order passed u/ss 147, 144, and 144B, the order u/s 148A(d), and the notices u/s 148A(b) were quashed and set aside, favoring the assessee.
Assessment/reassessment proceedings against an insolvent company were quashed. A resolution plan was approved by the Tribunal u/s 30(6) of the Insolvency and Bankruptcy Code. The claim lodged by the Deputy Commissioner of Income Tax was verified and admitted during the NCLT proceedings. As per the Code's provisions, no person can initiate or continue proceedings regarding claims for dues relating to the period prior to the resolution plan's approval. Consequently, the Assessment Order passed u/ss 147, 144, and 144B, the order u/s 148A(d), and the notices u/s 148A(b) were quashed and set aside, favoring the assessee.
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