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...
Levy of penalty u/s 112(a) - under-invoicing the import goods - Power of DRI to issue SCN - In the present case, the order was adjudicated by the Joint Commissioner of Customs and there is no dispute that he had the jurisdiction to adjudicate the question of levy of penalty under Section 122 of the Customs Act - the question as to whether the officers of DRI are proper officers for issuance of notice u/s 28 of the Customs Act does not arise in the present case. - HC
Levy of penalty u/s 112(a) - under-invoicing the import goods - Power of DRI to issue SCN - In the present case, the order was adjudicated by the Joint Commissioner of Customs and there is no dispute that he had the jurisdiction to adjudicate the question of levy of penalty under Section 122 of the Customs Act - the question as to whether the officers of DRI are proper officers for issuance of notice u/s 28 of the Customs Act does not arise in the present case. - HC
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