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...
Period of limitation for refund claim - Constitutional Validity of Rule 90(3) - The period of limitation thus falling between 15th March, 2020 to 2nd October, 2021 is required to be excluded. If the said period between 15th March, 2020 and 2nd October, 2021 is excluded, the third refund application filed by the petitioner was within the period of limitation prescribed under the said circular dated 19th November, 2029 read with 54(1) of the Central Goods and Services Tax Rules, 2017. - HC
Period of limitation for refund claim - Constitutional Validity of Rule 90(3) - The period of limitation thus falling between 15th March, 2020 to 2nd October, 2021 is required to be excluded. If the said period between 15th March, 2020 and 2nd October, 2021 is excluded, the third refund application filed by the petitioner was within the period of limitation prescribed under the said circular dated 19th November, 2029 read with 54(1) of the Central Goods and Services Tax Rules, 2017. - HC
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