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...
Levy of penalty u/s 26 of CER - supply of invoices without supply of capital goods - The investigation was conducted five years after the goods were supplied. Once the goods were supplied by the appellant, they are beyond its control. Inconsistency in the invoices ledger of the transporter also does not carry the case of the Revenue any further because transportation was the responsibility of the buyer and not of the appellant. - AT
Levy of penalty u/s 26 of CER - supply of invoices without supply of capital goods - The investigation was conducted five years after the goods were supplied. Once the goods were supplied by the appellant, they are beyond its control. Inconsistency in the invoices ledger of the transporter also does not carry the case of the Revenue any further because transportation was the responsibility of the buyer and not of the appellant. - AT
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