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...
Section 115BAB gives a new manufacturing domestic company's option continuing effect: once validly exercised in the first eligible year within time, it applies to subsequent assessment years and cannot be withdrawn. On the facts, the assessee had already exercised the option in the preceding year, so the concessional regime continued for the year under consideration. The benefit could not be denied merely because the original return for that year was later treated as invalid under section 139(9), as that technical defect did not convert the year into a fresh first-year exercise of option.
Section 115BAB gives a new manufacturing domestic company's option continuing effect: once validly exercised in the first eligible year within time, it applies to subsequent assessment years and cannot be withdrawn. On the facts, the assessee had already exercised the option in the preceding year, so the concessional regime continued for the year under consideration. The benefit could not be denied merely because the original return for that year was later treated as invalid under section 139(9), as that technical defect did not convert the year into a fresh first-year exercise of option.
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