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...
A GST refund deficiency memo in Form RFD-03 must identify the precise document defects; a vague statement that supporting papers are incomplete is insufficient because the applicant cannot effectively cure unspecified deficiencies. The memo cannot be used to reject the refund claim without particulars, and if treated as a rejection, that reasoning remains unsustainable. The proper course is to communicate the specific defects, allow rectification within time, and then decide the refund claim afresh by a speaking order.
A GST refund deficiency memo in Form RFD-03 must identify the precise document defects; a vague statement that supporting papers are incomplete is insufficient because the applicant cannot effectively cure unspecified deficiencies. The memo cannot be used to reject the refund claim without particulars, and if treated as a rejection, that reasoning remains unsustainable. The proper course is to communicate the specific defects, allow rectification within time, and then decide the refund claim afresh by a speaking order.
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