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...
Adjudication proceedings / Tax Administration - internal process of the customs administration - Valuation - Loading of value - The first appellate authority, in exercise of powers under section 128 of Customs Act, 1962, should have restricted itself to orders that cause grievance - there is an implied lack of jurisdiction for the Tribunal too to consider the merit of either side. It would, therefore, be appropriate for the first appellate authority to consider remedies appropriate to the grievance, if any and to the extent permitted by statutory conferment. - AT
Adjudication proceedings / Tax Administration - internal process of the customs administration - Valuation - Loading of value - The first appellate authority, in exercise of powers under section 128 of Customs Act, 1962, should have restricted itself to orders that cause grievance - there is an implied lack of jurisdiction for the Tribunal too to consider the merit of either side. It would, therefore, be appropriate for the first appellate authority to consider remedies appropriate to the grievance, if any and to the extent permitted by statutory conferment. - AT
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