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...
HC partially set aside assessment order concerning disputed "Security Wages" treatment, finding procedural deficiency as this issue was not specifically mentioned in show cause notice which only referenced "Administration Expenses." Court determined petitioner was denied natural justice by not receiving opportunity for personal hearing on security wages matter. Order remanded to respondent for fresh consideration specifically regarding security wages component. While granting liberty to file appeal on remaining assessment issues, HC cautioned against piecemeal appeals. Original assessment dated 30.08.2024 remains valid on all other aspects pending potential comprehensive appeal by petitioner.
HC partially set aside assessment order concerning disputed "Security Wages" treatment, finding procedural deficiency as this issue was not specifically mentioned in show cause notice which only referenced "Administration Expenses." Court determined petitioner was denied natural justice by not receiving opportunity for personal hearing on security wages matter. Order remanded to respondent for fresh consideration specifically regarding security wages component. While granting liberty to file appeal on remaining assessment issues, HC cautioned against piecemeal appeals. Original assessment dated 30.08.2024 remains valid on all other aspects pending potential comprehensive appeal by petitioner.
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