Charitable registration renewal cannot become an assessment of receipts, profitability or annual exemption compliance, requiring renewal and donation ...
AMP expenditure for own business is not an international transaction without an associated-enterprise arrangement, eliminating transfer pricing adjust...
Customs valuation must use comparable contemporary imports, while confiscation fines and penalties require proportionate recalculation on reassessed v...
Depositor-protection proceedings prevail over corporate insolvency, while liquidators may recover chit receivables using copies of seized company reco...
Intermediary service classification fails where overseas admission facilitation is supplied independently, preserving export treatment and small-provi...
Satellite transponder bandwidth is telecommunication, not Business Support Service; foreign non-telegraph providers triggered no service tax liability...
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An approved resolution plan binds governmental and statutory authorities and operates on a clean-slate basis for tax proceedings relating to pre-approval periods. Where plan clauses expressly extinguish and require withdrawal of pending tax proceedings concerning the corporate debtor, affiliates and subsidiaries, income-tax jurisdiction cannot be exercised inconsistently with the plan. A legal plea based on subsequent undisputed approval of the plan may be admitted in appellate proceedings where it goes to the root of the matter and requires no fresh factual enquiry. Income-tax appeals for the relevant pre-approval assessment years cannot continue; the taxpayer's appeals succeed on this preliminary issue, the Revenue's appeals fail, and merits issues remain open.
An approved resolution plan binds governmental and statutory authorities and operates on a clean-slate basis for tax proceedings relating to pre-approval periods. Where plan clauses expressly extinguish and require withdrawal of pending tax proceedings concerning the corporate debtor, affiliates and subsidiaries, income-tax jurisdiction cannot be exercised inconsistently with the plan. A legal plea based on subsequent undisputed approval of the plan may be admitted in appellate proceedings where it goes to the root of the matter and requires no fresh factual enquiry. Income-tax appeals for the relevant pre-approval assessment years cannot continue; the taxpayer's appeals succeed on this preliminary issue, the Revenue's appeals fail, and merits issues remain open.
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