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...
Recovery of GST interest and penalty failed where the order-in-original was not matched by Form GST DRC-07, which reflected only tax and omitted the additional demand. On that discrepancy, the garnishee notice in Form GST DRC-13 was unsustainable in its present form and was set aside. The respondents were left free to rectify Form GST DRC-07, and the taxpayer was left to pursue the remedy available in law thereafter.
Recovery of GST interest and penalty failed where the order-in-original was not matched by Form GST DRC-07, which reflected only tax and omitted the additional demand. On that discrepancy, the garnishee notice in Form GST DRC-13 was unsustainable in its present form and was set aside. The respondents were left free to rectify Form GST DRC-07, and the taxpayer was left to pursue the remedy available in law thereafter.
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