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 amount illegally collected from the petitioner - Self-ascertainment under Section 74(5) of CGST Act - Amount paid under coercion - Right of Bona fide Tax Payer to be treated with dignity - The stand of the respondents is ambiguous as self-ascertainment is put forward only as defence to the assertion of the petitioner that the payment of amount has been made involuntarily - the contention of payment being made by way of self-ascertainment is liable to be rejected. - Lapse of time and lack of conclusion of investigation has only exacerbated the situation conferring upon the petitioners a right to seek for refund of the amount. - The refund applications at Annexure-'Q' are to be considered and suitable orders be passed - HC
Refund of amount illegally collected from the petitioner - Self-ascertainment under Section 74(5) of CGST Act - Amount paid under coercion - Right of Bona fide Tax Payer to be treated with dignity - The stand of the respondents is ambiguous as self-ascertainment is put forward only as defence to the assertion of the petitioner that the payment of amount has been made involuntarily - the contention of payment being made by way of self-ascertainment is liable to be rejected. - Lapse of time and lack of conclusion of investigation has only exacerbated the situation conferring upon the petitioners a right to seek for refund of the amount. - The refund applications at Annexure-'Q' are to be considered and suitable orders be passed - HC
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