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...
An unauthenticated transfer pricing order issued without signature was held invalid and non est in law because no signed order of the Transfer Pricing Officer was placed on record. The Tribunal rejected reliance on the faceless assessment procedure as irrelevant on the facts noted. As the order under section 92CA(3) lacked authentication, it could not be recognised in law, and the impugned assessments for both assessment years were quashed. The assessee's appeals were therefore allowed on this legal ground.
An unauthenticated transfer pricing order issued without signature was held invalid and non est in law because no signed order of the Transfer Pricing Officer was placed on record. The Tribunal rejected reliance on the faceless assessment procedure as irrelevant on the facts noted. As the order under section 92CA(3) lacked authentication, it could not be recognised in law, and the impugned assessments for both assessment years were quashed. The assessee's appeals were therefore allowed on this legal ground.
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