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...
Refund of accumulated CENVAT Credit - After the introduction of GST, the appellant is not able to take recredit of the said amount. Thus, the alternative prayer put forward at the time of argument is to grant refund taking into consideration the practical difficulty in taking recredit after introduction of GST. There was no adjudication in regard to the application of Sec. 142 of GST Act, 2017. - The Tribunal being a creature of the statute cannot grant reliefs extraneous to the adjudication. - AT
Refund of accumulated CENVAT Credit - After the introduction of GST, the appellant is not able to take recredit of the said amount. Thus, the alternative prayer put forward at the time of argument is to grant refund taking into consideration the practical difficulty in taking recredit after introduction of GST. There was no adjudication in regard to the application of Sec. 142 of GST Act, 2017. - The Tribunal being a creature of the statute cannot grant reliefs extraneous to the adjudication. - AT
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