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...
Where a statutory rectification remedy is available against an order disallowing input tax credit, the writ court will not examine whether the claim falls within the retrospectively extended cases at that stage. The Court held that the issue should first be considered by the competent authority in rectification proceedings, particularly where paragraph 3.5 provides such a remedy after an order under section 73 and no appeal has been filed. The writ petition was disposed of without deciding the merits, and the petitioner was given liberty to file a rectification application, which the authority must hear and decide in accordance with law.
Where a statutory rectification remedy is available against an order disallowing input tax credit, the writ court will not examine whether the claim falls within the retrospectively extended cases at that stage. The Court held that the issue should first be considered by the competent authority in rectification proceedings, particularly where paragraph 3.5 provides such a remedy after an order under section 73 and no appeal has been filed. The writ petition was disposed of without deciding the merits, and the petitioner was given liberty to file a rectification application, which the authority must hear and decide in accordance with law.
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