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...
Legality and validity of the provisional attachment of the bank account of the petitioner - It is not a case of complete evasion of tax by the petitioner - According to the Revenue, there is a short-payment of the tax due - It is mentioned that the quantum mentioned by the respondents is only a provisional figure even before issuance of show cause notice; not to speak of any adjudication order. In such a case, attaching bank account of the petitioner is not at all justified - HC
Legality and validity of the provisional attachment of the bank account of the petitioner - It is not a case of complete evasion of tax by the petitioner - According to the Revenue, there is a short-payment of the tax due - It is mentioned that the quantum mentioned by the respondents is only a provisional figure even before issuance of show cause notice; not to speak of any adjudication order. In such a case, attaching bank account of the petitioner is not at all justified - HC
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