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...
Validity of dropping of demand - As such there was no way that Commissioner could have confirmed a lesser amount than the amount paid by the appellants. Moreover, the appellants have paid 100% tax under VCES 2013; the payment was not rejected by designated authority and in terms of section 109 of VCES 2013, the assessee is not entitled for any refund. Under the circumstances appropriation of duty is an empty formality. - AT
Validity of dropping of demand - As such there was no way that Commissioner could have confirmed a lesser amount than the amount paid by the appellants. Moreover, the appellants have paid 100% tax under VCES 2013; the payment was not rejected by designated authority and in terms of section 109 of VCES 2013, the assessee is not entitled for any refund. Under the circumstances appropriation of duty is an empty formality. - AT
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