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...
Refund allowed in an assessee's appeal may be released despite a pending departmental appeal before the Tribunal where no hearing has been fixed. Withholding was considered unwarranted given the petitioner's status as a manufacturing company and its undertaking to deposit any liability ultimately arising if the departmental appeal succeeds. Release was made conditional on furnishing that undertaking and a certified copy of the order, with the Revenue directed to issue the refund within six weeks. The departmental appeal remained subject to adjudication by the Tribunal.
Refund allowed in an assessee's appeal may be released despite a pending departmental appeal before the Tribunal where no hearing has been fixed. Withholding was considered unwarranted given the petitioner's status as a manufacturing company and its undertaking to deposit any liability ultimately arising if the departmental appeal succeeds. Release was made conditional on furnishing that undertaking and a certified copy of the order, with the Revenue directed to issue the refund within six weeks. The departmental appeal remained subject to adjudication by the Tribunal.
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