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...
Corporate guarantee taxability under GST was remitted for fresh assessment because the assessing authority had not properly considered the petitioner's reliance on applicable GST circulars, the contention that only 1% of turnover was taxable, and the earlier Madras HC ruling cited in support. The Court held that these aspects required examination and that the assessment could not stand on the corporate guarantee issue alone. The impugned order was therefore set aside only to that limited extent, with directions for fresh orders after hearing the petitioner and considering supporting material; all other findings were left undisturbed.
Corporate guarantee taxability under GST was remitted for fresh assessment because the assessing authority had not properly considered the petitioner's reliance on applicable GST circulars, the contention that only 1% of turnover was taxable, and the earlier Madras HC ruling cited in support. The Court held that these aspects required examination and that the assessment could not stand on the corporate guarantee issue alone. The impugned order was therefore set aside only to that limited extent, with directions for fresh orders after hearing the petitioner and considering supporting material; all other findings were left undisturbed.
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