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...
Writ jurisdiction against CGST Orders-in-Original is unavailable where the statutory appeal provides an efficacious and comprehensive remedy for reviewing facts, law, evidence and adjudicatory correctness. Objections concerning hearing, notice service, technical difficulties, evidentiary authentication, corroboration, cross-examination and voluntary payment require record-based factual assessment by the appellate authority. Neither patent lack of jurisdiction nor a manifest, common breach of natural justice was established to justify bypassing that remedy. Petitioners who had already invoked the statutory appeal could not simultaneously pursue writ relief over the same order without exceptional circumstances. The writ petitions were dismissed, with merits left open for appellate consideration, including any request to exclude time spent in writ proceedings according to law.
Writ jurisdiction against CGST Orders-in-Original is unavailable where the statutory appeal provides an efficacious and comprehensive remedy for reviewing facts, law, evidence and adjudicatory correctness. Objections concerning hearing, notice service, technical difficulties, evidentiary authentication, corroboration, cross-examination and voluntary payment require record-based factual assessment by the appellate authority. Neither patent lack of jurisdiction nor a manifest, common breach of natural justice was established to justify bypassing that remedy. Petitioners who had already invoked the statutory appeal could not simultaneously pursue writ relief over the same order without exceptional circumstances. The writ petitions were dismissed, with merits left open for appellate consideration, including any request to exclude time spent in writ proceedings according to law.
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