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...
Non-disposal of an assessee's objections to reassessment reopening before completion of the assessment vitiates the reassessment, because disposal by a separate speaking order is a mandatory requirement and not a mere procedural formality. Applying its earlier decision in ITO v. Hardeep Singh, the ITAT held that the Assessing Officer had not decided the objections before finalising the reassessment. The annulment of the reassessment was therefore upheld, and the Revenue's reliance on Home Finders Housing Ltd. was not accepted.
Non-disposal of an assessee's objections to reassessment reopening before completion of the assessment vitiates the reassessment, because disposal by a separate speaking order is a mandatory requirement and not a mere procedural formality. Applying its earlier decision in ITO v. Hardeep Singh, the ITAT held that the Assessing Officer had not decided the objections before finalising the reassessment. The annulment of the reassessment was therefore upheld, and the Revenue's reliance on Home Finders Housing Ltd. was not accepted.
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