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...
Valuation of imported goods - The authorities have nowhere given any acceptable reasons as to why they jumped to adopt Rule 4 ibid. and the valuation prescribed thereunder, instead of following the Rules sequentially. From the records, nowhere it is seen that the appellant was furnished with the NIDB data or whatsoever that was relied upon for enhancement of the value, for rebuttal, which is clearly in violation of the principles of natural justice. - AT
Valuation of imported goods - The authorities have nowhere given any acceptable reasons as to why they jumped to adopt Rule 4 ibid. and the valuation prescribed thereunder, instead of following the Rules sequentially. From the records, nowhere it is seen that the appellant was furnished with the NIDB data or whatsoever that was relied upon for enhancement of the value, for rebuttal, which is clearly in violation of the principles of natural justice. - AT
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