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...
Rejection of declared FOB value and denial of drawback for readymade garments exported under 63 shipping bills were unsustainable because the proceedings relied exclusively on an investigation into separate March 2017 exports. Export remittances matching the declared FOB value had been received, while departmental costing material did not establish overvaluation. No independent enquiry addressed the 63 shipping bills. Consequently, the demand, FOB-value rejection and penalties were set aside, and the appeal succeeded with consequential relief.
Rejection of declared FOB value and denial of drawback for readymade garments exported under 63 shipping bills were unsustainable because the proceedings relied exclusively on an investigation into separate March 2017 exports. Export remittances matching the declared FOB value had been received, while departmental costing material did not establish overvaluation. No independent enquiry addressed the 63 shipping bills. Consequently, the demand, FOB-value rejection and penalties were set aside, and the appeal succeeded with consequential relief.
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