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...
Transfer of Un-utilised cenvat credit balance - amalgamation - Since the effective date of the transfer is 01.06.2005, which has been specifically mentioned in the order dated 09.10.2006 of the Hon’ble Delhi High Court, there is no scope of transfer of any cenvat credit balance lying in the cenvat credit account of M/s. M/s. Karamchand Appliances Pvt. Ltd. to the appellant prior to such date. - AT
Transfer of Un-utilised cenvat credit balance - amalgamation - Since the effective date of the transfer is 01.06.2005, which has been specifically mentioned in the order dated 09.10.2006 of the Hon’ble Delhi High Court, there is no scope of transfer of any cenvat credit balance lying in the cenvat credit account of M/s. M/s. Karamchand Appliances Pvt. Ltd. to the appellant prior to such date. - AT
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