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...
Refund - Doctrine of unjust enrichment - It is on record that the amounts were deducted from their bills and the client had forced the Appellant to make the remittance to the Government. In such a case, when it is clear that no amount was recovered from the client and this amount has been remitted by way of GAR-7 Challans, there is no possibility of any unjust enrichment accruing to the Appellant, if refund claim is sanctioned. - AT
Refund - Doctrine of unjust enrichment - It is on record that the amounts were deducted from their bills and the client had forced the Appellant to make the remittance to the Government. In such a case, when it is clear that no amount was recovered from the client and this amount has been remitted by way of GAR-7 Challans, there is no possibility of any unjust enrichment accruing to the Appellant, if refund claim is sanctioned. - AT
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