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...
Finality of an earlier judicial determination prevented the Department from reopening the applicable compounding guidelines when calculating the compounding fee. The article explains that a direction to quantify the fee required calculation rather than fresh adjudication, and that statutory instructions on compounding could not displace a binding inter partes finding that the 2008 CBDT Guidelines governed the application. It further notes that the 2024 Guidelines on fresh applications were limited to applications rejected for specified curable defects and did not cover applications rejected on merits. The fee was therefore to be recomputed under the 2008 Guidelines after crediting the amount already paid.
Finality of an earlier judicial determination prevented the Department from reopening the applicable compounding guidelines when calculating the compounding fee. The article explains that a direction to quantify the fee required calculation rather than fresh adjudication, and that statutory instructions on compounding could not displace a binding inter partes finding that the 2008 CBDT Guidelines governed the application. It further notes that the 2024 Guidelines on fresh applications were limited to applications rejected for specified curable defects and did not cover applications rejected on merits. The fee was therefore to be recomputed under the 2008 Guidelines after crediting the amount already paid.
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