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...
CBDT's beneficial circulars on condonation of delay for filing Form 10-IC were construed to apply to pending applications and to extend the framework prospectively, but not to revive cases where the three-year period had already expired. For AY 2020-21, the assessee was required to seek condonation within three years from the end of that assessment year, i.e. by 31.03.2024. Although liberal interpretation applies to beneficial circulars, it cannot go beyond their clear wording. An application filed on 20.01.2025 was therefore outside the circular scheme and was not entertainable under section 119(2)(b).
CBDT's beneficial circulars on condonation of delay for filing Form 10-IC were construed to apply to pending applications and to extend the framework prospectively, but not to revive cases where the three-year period had already expired. For AY 2020-21, the assessee was required to seek condonation within three years from the end of that assessment year, i.e. by 31.03.2024. Although liberal interpretation applies to beneficial circulars, it cannot go beyond their clear wording. An application filed on 20.01.2025 was therefore outside the circular scheme and was not entertainable under section 119(2)(b).
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