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...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
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Effective communication of a GST adjudication order is examined in relation to delay in filing a statutory appeal where the order was uploaded only on the GST portal. The notes state that, although the Appellate Authority is bound by the limitation period under Section 107 of the RGST/CGST Act, delay may be condoned where circumstances beyond the taxpayer's control prevented timely filing and denial of merits adjudication would cause grave prejudice. The appeal was directed to be entertained and decided on merits if filed within the period specified by the Court.
Effective communication of a GST adjudication order is examined in relation to delay in filing a statutory appeal where the order was uploaded only on the GST portal. The notes state that, although the Appellate Authority is bound by the limitation period under Section 107 of the RGST/CGST Act, delay may be condoned where circumstances beyond the taxpayer's control prevented timely filing and denial of merits adjudication would cause grave prejudice. The appeal was directed to be entertained and decided on merits if filed within the period specified by the Court.
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