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...
Service of a show cause notice through the GST common portal was treated as valid where the taxpayers later admitted the notice was available there, so the non-service challenge failed and the best judgment assessment stood. The limitation objection also failed: the court accepted that lesser tax payment despite knowledge of the applicable rate amounted to suppression, attracting the extended period, and relied on the notification extending the annual return due date to hold that the order was passed within time. The writ petition was dismissed and the order-in-original upheld.
Service of a show cause notice through the GST common portal was treated as valid where the taxpayers later admitted the notice was available there, so the non-service challenge failed and the best judgment assessment stood. The limitation objection also failed: the court accepted that lesser tax payment despite knowledge of the applicable rate amounted to suppression, attracting the extended period, and relied on the notification extending the annual return due date to hold that the order was passed within time. The writ petition was dismissed and the order-in-original upheld.
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