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...
Drawback Brand Rate and Special Brand Rate applications filed after the initial period but within twelve months of the Let Export Order require liberal consideration because the drawback scheme is beneficial in nature. A narrow or technical approach to delay within the statutorily extendable period is inappropriate. Delay in the relevant applications was condoned, and the applications were remanded for consideration on merits and fixation of the applicable drawback rate in accordance with law, with consequential relief.
Drawback Brand Rate and Special Brand Rate applications filed after the initial period but within twelve months of the Let Export Order require liberal consideration because the drawback scheme is beneficial in nature. A narrow or technical approach to delay within the statutorily extendable period is inappropriate. Delay in the relevant applications was condoned, and the applications were remanded for consideration on merits and fixation of the applicable drawback rate in accordance with law, with consequential relief.
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