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...
Effective service of a show cause notice requires more than a portal display: if the notice is not placed in the prescribed "View Notices and Orders" window and no copy is separately served, the recipient is denied a reasonable opportunity to reply. Absence of a personal hearing before adjudication further breaches natural justice and vitiates the consequential order. Where the defect goes to procedural fairness, the High Court may entertain writ jurisdiction despite an alternate appellate remedy, quash the notice and order, and remit the matter for fresh adjudication after reply and hearing.
Effective service of a show cause notice requires more than a portal display: if the notice is not placed in the prescribed "View Notices and Orders" window and no copy is separately served, the recipient is denied a reasonable opportunity to reply. Absence of a personal hearing before adjudication further breaches natural justice and vitiates the consequential order. Where the defect goes to procedural fairness, the High Court may entertain writ jurisdiction despite an alternate appellate remedy, quash the notice and order, and remit the matter for fresh adjudication after reply and hearing.
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