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...
The dominant issue was whether an assessment framed for FY 2024-2025 pursuant to a show cause notice issued under s.74, instead of the applicable s.74A, was legally sustainable. The Court held that issuance of the notice and consequential assessment under s.74 lacked authority of law where s.74A governed the period; therefore, the assessment order was set aside. To avoid futile remand and limitation complications, the Court directed that the existing notice be treated as a notice under s.74A, required the taxpayer to file a reply on that basis, and ordered adjudication afresh on merits. - HC
The dominant issue was whether an assessment framed for FY 2024-2025 pursuant to a show cause notice issued under s.74, instead of the applicable s.74A, was legally sustainable. The Court held that issuance of the notice and consequential assessment under s.74 lacked authority of law where s.74A governed the period; therefore, the assessment order was set aside. To avoid futile remand and limitation complications, the Court directed that the existing notice be treated as a notice under s.74A, required the taxpayer to file a reply on that basis, and ordered adjudication afresh on merits. - HC
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