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...
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Zero-rated IGST refund claims routed through a Foreign Post Office were treated as enforceable statutory entitlements. Reading the IGST Act with the CGST Rules, the Court stated that taxpayers had a right to seek refund and that the respondents were responsible for processing the claim. The absence of an available upload mechanism for the relevant period, and shifting responsibility between customs, the Foreign Post Office and the Board, was treated as an administrative failure that could not defeat a statutory refund claim. The matter was left pending on an assurance of further action.
Zero-rated IGST refund claims routed through a Foreign Post Office were treated as enforceable statutory entitlements. Reading the IGST Act with the CGST Rules, the Court stated that taxpayers had a right to seek refund and that the respondents were responsible for processing the claim. The absence of an available upload mechanism for the relevant period, and shifting responsibility between customs, the Foreign Post Office and the Board, was treated as an administrative failure that could not defeat a statutory refund claim. The matter was left pending on an assurance of further action.
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