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...
Extended period of limitation - Suppression of facts or not - The returns contained all the requisite details as that of the invoice numbers, the amount of invoice, the amount of service tax etc. Nothing has stopped Department to look into those invoices - the allegation of suppression of facts against the appellant are without any basis. Accordingly the foremost reason for invoking the extended period of limitation remains not available with the Department. Otherwise also the onus is always upon the Department to prove the alleged misrepresentation or suppression of fact that too with an intent to evading duty - AT
Extended period of limitation - Suppression of facts or not - The returns contained all the requisite details as that of the invoice numbers, the amount of invoice, the amount of service tax etc. Nothing has stopped Department to look into those invoices - the allegation of suppression of facts against the appellant are without any basis. Accordingly the foremost reason for invoking the extended period of limitation remains not available with the Department. Otherwise also the onus is always upon the Department to prove the alleged misrepresentation or suppression of fact that too with an intent to evading duty - AT
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