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...
GST liability of a deceased taxable person may be adjudicated after death, and the HC read the statutory scheme to allow fresh proceedings against the legal heir under the recovery provisions. Section 93 was held to cover discontinued businesses and to permit determination of tax, interest or penalty after the taxpayer's death, with recovery confined to the inherited estate. The Court also held that the phrase "person chargeable with tax" is wider than "taxable person" and includes a legal heir where liability is made recoverable under the Act. The Court declined to limit Section 93 to cases where notice had already been issued during the deceased's lifetime.
GST liability of a deceased taxable person may be adjudicated after death, and the HC read the statutory scheme to allow fresh proceedings against the legal heir under the recovery provisions. Section 93 was held to cover discontinued businesses and to permit determination of tax, interest or penalty after the taxpayer's death, with recovery confined to the inherited estate. The Court also held that the phrase "person chargeable with tax" is wider than "taxable person" and includes a legal heir where liability is made recoverable under the Act. The Court declined to limit Section 93 to cases where notice had already been issued during the deceased's lifetime.
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