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...
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Maintainability of wrt petition before HC where option for filing Revision u/s 264 is available - Rejection of Refund of excess amount paid as tax - There are no substance in the submission of the Petitioner that no revision would be available against the impugned order as it is not an order passed under the Act. Thus, remedy of revision u/s 264(1) would be available to the Petitioner.
Maintainability of wrt petition before HC where option for filing Revision u/s 264 is available - Rejection of Refund of excess amount paid as tax - There are no substance in the submission of the Petitioner that no revision would be available against the impugned order as it is not an order passed under the Act. Thus, remedy of revision u/s 264(1) would be available to the Petitioner.
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