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...
Refund of unutilized CENVAT Credit - rejection of refund on the ground that credit was transferred to GST regime through TRAN-1 - it is not a case that the appellant has carried forward ineligible credit into TRAN-1. The credit so transferred by the appellant were eligible credit; the refund was rejected on the ground of time bar and subsequently rejected under GST by invoking the Section 142(3) of the CGST Act 2017. - Matter remanded back to the original authority with a direction that TRAN-1 credit taken by the appellant be directed to be reversed and thereafter the original authority will consider the directions given - AT
Refund of unutilized CENVAT Credit - rejection of refund on the ground that credit was transferred to GST regime through TRAN-1 - it is not a case that the appellant has carried forward ineligible credit into TRAN-1. The credit so transferred by the appellant were eligible credit; the refund was rejected on the ground of time bar and subsequently rejected under GST by invoking the Section 142(3) of the CGST Act 2017. - Matter remanded back to the original authority with a direction that TRAN-1 credit taken by the appellant be directed to be reversed and thereafter the original authority will consider the directions given - AT
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