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...
Section 74 does not permit a single show-cause notice to club multiple financial years, because limitation is linked to each relevant financial year and a consolidated notice would unlawfully extend the five-year period for earlier years. The impugned notice and consequential order were therefore treated as de hors the statute and without jurisdiction. The alternative-remedy rule was also held to be only a self-imposed restraint: where the defect is ex facie jurisdictional and apparent on the record, writ relief remains maintainable despite an available statutory appeal.
Section 74 does not permit a single show-cause notice to club multiple financial years, because limitation is linked to each relevant financial year and a consolidated notice would unlawfully extend the five-year period for earlier years. The impugned notice and consequential order were therefore treated as de hors the statute and without jurisdiction. The alternative-remedy rule was also held to be only a self-imposed restraint: where the defect is ex facie jurisdictional and apparent on the record, writ relief remains maintainable despite an available statutory appeal.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4792
Join Channel
TaxTMI 
