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...
The HC set aside the appellate order rejecting the appeal as time-barred because the authority failed to consider the petitioner's pleaded grounds for condonation of delay, including the assertion that filing was delayed due to counsel's mistake after documents had been handed over. Rejection of limitation without dealing with these material explanations amounted to non-consideration of relevant contentions and a non-reasoned decision. The matter was remitted to the appellate authority for fresh consideration in accordance with law after notice to the petitioner.
The HC set aside the appellate order rejecting the appeal as time-barred because the authority failed to consider the petitioner's pleaded grounds for condonation of delay, including the assertion that filing was delayed due to counsel's mistake after documents had been handed over. Rejection of limitation without dealing with these material explanations amounted to non-consideration of relevant contentions and a non-reasoned decision. The matter was remitted to the appellate authority for fresh consideration in accordance with law after notice to the petitioner.
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