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 claim of SAD - Principles of Unjust Enrichment - Scope of CA certificate - Refund already sanctioned by the lower authorities - Merely stating that ‘the review order was issued on grounds that the certificate is not emphatic to the effect that unjust enrichment is not applicable and the incidence of duty was not passed on to the ultimate customer’, will not suffice, a more focused approach is required. - Revenue appeal rejected - AT
Refund claim of SAD - Principles of Unjust Enrichment - Scope of CA certificate - Refund already sanctioned by the lower authorities - Merely stating that ‘the review order was issued on grounds that the certificate is not emphatic to the effect that unjust enrichment is not applicable and the incidence of duty was not passed on to the ultimate customer’, will not suffice, a more focused approach is required. - Revenue appeal rejected - AT
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