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...
Estimation of exempted turnover and taxable turnover - SAIL was unable to produce materials to show to what extent the canteen sales included sale of tax-free goods and first point tax paid goods - In the absence of SAIL producing records relevant to the issue, even in this Court, the estimation that 70% of the sales was of cooked food items and 30% of tea, coffee and snacks etc. cannot be said to be arbitrary. - HC
Estimation of exempted turnover and taxable turnover - SAIL was unable to produce materials to show to what extent the canteen sales included sale of tax-free goods and first point tax paid goods - In the absence of SAIL producing records relevant to the issue, even in this Court, the estimation that 70% of the sales was of cooked food items and 30% of tea, coffee and snacks etc. cannot be said to be arbitrary. - HC
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