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...
Section 75(4) requires a personal hearing where an adverse decision is contemplated, and a show-cause notice for short-paid GST indicates such contemplation without requiring a separate written request. An assessment order issued without considering the taxpayer's reply, despite the reply and hearing request being on record, reflects non-application of mind. The assessment order was set aside, with fresh proceedings permitted from consideration of the reply after granting a personal hearing in accordance with law. Exemplary costs were directed against the respondent authority for treating the matter as though no reply had been filed.
Section 75(4) requires a personal hearing where an adverse decision is contemplated, and a show-cause notice for short-paid GST indicates such contemplation without requiring a separate written request. An assessment order issued without considering the taxpayer's reply, despite the reply and hearing request being on record, reflects non-application of mind. The assessment order was set aside, with fresh proceedings permitted from consideration of the reply after granting a personal hearing in accordance with law. Exemplary costs were directed against the respondent authority for treating the matter as though no reply had been filed.
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