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...
Contractual reimbursement of incremental GST under pre-GST or transitional works contracts remains a matter between the contractor and the employer, and does not alter the statutory GST scheme. The text states that directions requiring revised returns, or waiving interest, penalty or limitation, cannot be issued contrary to the GST enactments, because levy, assessment, recovery and enforcement must follow the statute. It also clarifies that tax authorities have no role in the private reimbursement dispute, so any reimbursement direction is confined to the employer and cannot be read as fastening liability on the State or tax administration.
Contractual reimbursement of incremental GST under pre-GST or transitional works contracts remains a matter between the contractor and the employer, and does not alter the statutory GST scheme. The text states that directions requiring revised returns, or waiving interest, penalty or limitation, cannot be issued contrary to the GST enactments, because levy, assessment, recovery and enforcement must follow the statute. It also clarifies that tax authorities have no role in the private reimbursement dispute, so any reimbursement direction is confined to the employer and cannot be read as fastening liability on the State or tax administration.
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