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...
Electronic service of GST show-cause notices and adjudication orders requires more than uploading them to the 'View Additional Notices and Orders' tab of the GST Common Portal. Portal-only uploading does not constitute proper service under the CGST Act unless the recipient acknowledges receipt or responds. A retrospective amendment permitting functions under the GST Rules to be performed through the portal does not expand the portal's specified functions or replace formal statutory service. The writ petition was disposed of consistently with the established position on deficient portal-only service.
Electronic service of GST show-cause notices and adjudication orders requires more than uploading them to the 'View Additional Notices and Orders' tab of the GST Common Portal. Portal-only uploading does not constitute proper service under the CGST Act unless the recipient acknowledges receipt or responds. A retrospective amendment permitting functions under the GST Rules to be performed through the portal does not expand the portal's specified functions or replace formal statutory service. The writ petition was disposed of consistently with the established position on deficient portal-only service.
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