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...
Effective service of GST notices requires more than portal upload where repeated communications receive no taxpayer response. Although portal uploading constitutes valid service, the assessing officer should consider other statutory modes under Section 169(1), preferably registered post with acknowledgement due, to ensure that notice reaches the taxpayer. An ex parte assessment without an effective opportunity to respond and a personal hearing risks avoidable litigation. The assessment was set aside and remanded for fresh consideration after objections are filed, with a clear 14-day notice for personal hearing and a merits-based decision.
Effective service of GST notices requires more than portal upload where repeated communications receive no taxpayer response. Although portal uploading constitutes valid service, the assessing officer should consider other statutory modes under Section 169(1), preferably registered post with acknowledgement due, to ensure that notice reaches the taxpayer. An ex parte assessment without an effective opportunity to respond and a personal hearing risks avoidable litigation. The assessment was set aside and remanded for fresh consideration after objections are filed, with a clear 14-day notice for personal hearing and a merits-based decision.
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