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 APA covering the relevant year required the Arm's Length Price for international transactions to be reconsidered with reference to the APA terms, so the Assessing Officer was directed to rework the transfer pricing adjustment in accordance with law. The MAT book profit adjustment was also sent back because the assessment order did not discuss the addition and the assessee had not been given an opportunity of hearing; the officer was directed to reconsider the book profit computation after hearing the assessee and in light of the section 143(1) intimation. The interest and fee computation was remanded for verification of the extended due date, and interest under section 234B was held mandatory, subject to consequential recomputation after giving effect to the revised figures.
An APA covering the relevant year required the Arm's Length Price for international transactions to be reconsidered with reference to the APA terms, so the Assessing Officer was directed to rework the transfer pricing adjustment in accordance with law. The MAT book profit adjustment was also sent back because the assessment order did not discuss the addition and the assessee had not been given an opportunity of hearing; the officer was directed to reconsider the book profit computation after hearing the assessee and in light of the section 143(1) intimation. The interest and fee computation was remanded for verification of the extended due date, and interest under section 234B was held mandatory, subject to consequential recomputation after giving effect to the revised figures.
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