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...
RTGS credits claimed as gold-sale proceeds were treated as a benami transaction because the appellant did not prove a prior business relationship with the remitting entities or independently corroborate invoices, purchase bills, ledgers and stock records. The undisputed cash deposit with the alleged benamidar, subsequent RTGS transfers, timing after demonetisation and bank records supported confirmation of the provisional attachment. Denial of cross-examination did not breach natural justice: no intermediary statement existed, the alleged benamidar had been made available but did not appear, and no actual prejudice was shown. The appeal was dismissed.
RTGS credits claimed as gold-sale proceeds were treated as a benami transaction because the appellant did not prove a prior business relationship with the remitting entities or independently corroborate invoices, purchase bills, ledgers and stock records. The undisputed cash deposit with the alleged benamidar, subsequent RTGS transfers, timing after demonetisation and bank records supported confirmation of the provisional attachment. Denial of cross-examination did not breach natural justice: no intermediary statement existed, the alleged benamidar had been made available but did not appear, and no actual prejudice was shown. The appeal was dismissed.
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