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...
Section 122(1A) is construed to cover "any person" other than the taxable person where that person retained the benefit of the contravening transactions and acted at whose instance they were done; on that basis, partners of a firm can be proceeded against if those factual conditions are recorded. The provision is treated as complementary to Section 122(1), not as creating a new independent offence, so it may apply to transactions predating 1 January 2021 if the show-cause notice was issued after the provision came into force. The writ challenge was rejected, while the petitioners were left free to contest the factual findings before the Appellate Tribunal.
Section 122(1A) is construed to cover "any person" other than the taxable person where that person retained the benefit of the contravening transactions and acted at whose instance they were done; on that basis, partners of a firm can be proceeded against if those factual conditions are recorded. The provision is treated as complementary to Section 122(1), not as creating a new independent offence, so it may apply to transactions predating 1 January 2021 if the show-cause notice was issued after the provision came into force. The writ challenge was rejected, while the petitioners were left free to contest the factual findings before the Appellate Tribunal.
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