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...
Denial of CENVAT Credit - Availing benefit of SVLRDS - adjustment/deduction the excise duty paid by the petitioners through utilizing Cenvat Credit at the time of investigation - this benefit cannot be denied on the ground that the period of limitation of one year has gone by, as under the benefit under Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 (annexure P-3), any amount deposited during enquiry has to be adjusted. - HC
Denial of CENVAT Credit - Availing benefit of SVLRDS - adjustment/deduction the excise duty paid by the petitioners through utilizing Cenvat Credit at the time of investigation - this benefit cannot be denied on the ground that the period of limitation of one year has gone by, as under the benefit under Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 (annexure P-3), any amount deposited during enquiry has to be adjusted. - HC
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