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...
An assessment or transfer pricing order passed in the name of a dissolved amalgamating company is void ab initio when the successor entity had already informed the tax authorities of the amalgamation and furnished the NCLT-approved scheme. Applying Maruti Suzuki India Ltd., the ITAT held that such an error is not a curable procedural defect under section 292B. The transfer pricing order, draft assessment order and final assessment order, all issued after dissolution in the name and PAN of the non-existent company, were therefore bad in law.
An assessment or transfer pricing order passed in the name of a dissolved amalgamating company is void ab initio when the successor entity had already informed the tax authorities of the amalgamation and furnished the NCLT-approved scheme. Applying Maruti Suzuki India Ltd., the ITAT held that such an error is not a curable procedural defect under section 292B. The transfer pricing order, draft assessment order and final assessment order, all issued after dissolution in the name and PAN of the non-existent company, were therefore bad in law.
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