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...
Validity of SCN - Admittedly, no such SCN is found in the file. Once, there is no such SCN found in the file, then, there was no sanction in law to make an Order-in-Original, particularly, after the period of nearly 18 years from the date of filing of the Bill of Entry and 12 ½ years from the date of the assessment, as contemplated by Sub-sections (1) and (2) of Section 18. - HC
Validity of SCN - Admittedly, no such SCN is found in the file. Once, there is no such SCN found in the file, then, there was no sanction in law to make an Order-in-Original, particularly, after the period of nearly 18 years from the date of filing of the Bill of Entry and 12 ½ years from the date of the assessment, as contemplated by Sub-sections (1) and (2) of Section 18. - HC
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