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...
Pending inquiry, audit verification, query letters and DRI investigation did not amount to a formal proceeding raising the same question, so the Section 28I bar on an advance ruling application was not triggered and the application was maintainable. On merits, Serial No. 19 of Notification No. 11/2021-Customs was construed with Section 25(1) to mean that NIL AIDC is available where exemption from basic customs duty is claimed and allowed, whether the BCD relief is full or partial. The benefit was held applicable to eligible AIFTA and SAFTA imports, subject to the relevant notification conditions, including a valid certificate of origin and compliance with CAROTAR.
Pending inquiry, audit verification, query letters and DRI investigation did not amount to a formal proceeding raising the same question, so the Section 28I bar on an advance ruling application was not triggered and the application was maintainable. On merits, Serial No. 19 of Notification No. 11/2021-Customs was construed with Section 25(1) to mean that NIL AIDC is available where exemption from basic customs duty is claimed and allowed, whether the BCD relief is full or partial. The benefit was held applicable to eligible AIFTA and SAFTA imports, subject to the relevant notification conditions, including a valid certificate of origin and compliance with CAROTAR.
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