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...
Condonation of delay in filing appeal before the Commissioner (Appeals) - Dismissal of appeal on the ground that the appeal was delayed by thirty three days - exclusion of the period during which the matter was pending before the High Court. - The Supreme court found merit in the appellant's argument and held that the delay in filing the appeal should be condoned under the proviso to sub-section 3A of Section 85 of the Finance Act, 1994. Consequently, the impugned orders were set aside, and the matter was restored to the file of the Commissioner (Appeals)
Condonation of delay in filing appeal before the Commissioner (Appeals) - Dismissal of appeal on the ground that the appeal was delayed by thirty three days - exclusion of the period during which the matter was pending before the High Court. - The Supreme court found merit in the appellant's argument and held that the delay in filing the appeal should be condoned under the proviso to sub-section 3A of Section 85 of the Finance Act, 1994. Consequently, the impugned orders were set aside, and the matter was restored to the file of the Commissioner (Appeals)
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