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...
HC ruled that the block period of six years for reassessment under Section 153C(1)(b) is to be calculated from 28.07.2022. The extended ten-year period is inapplicable in this case. The jurisdictional notice for Assessment Year 2016-17, falling beyond the six-year block period, was deemed unsustainable. Relying on prior judicial precedent, the court set aside the impugned notice, effectively invalidating the tax department's attempt to reopen the assessment beyond the prescribed statutory timeframe.
HC ruled that the block period of six years for reassessment under Section 153C(1)(b) is to be calculated from 28.07.2022. The extended ten-year period is inapplicable in this case. The jurisdictional notice for Assessment Year 2016-17, falling beyond the six-year block period, was deemed unsustainable. Relying on prior judicial precedent, the court set aside the impugned notice, effectively invalidating the tax department's attempt to reopen the assessment beyond the prescribed statutory timeframe.
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