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...
Extended period of limitation - liability of a subcontractor to pay service tax - The High court concluded that the interpretation issue regarding subcontractor liability was unsettled until a later decision in 2019. Therefore, the respondent's actions were considered bona fide, and the failure to disclose the payment of service tax did not constitute suppression of facts. - Consequently, the court upheld the Tribunal's decision to remit the case back to the Commissioner without invoking the proviso to extend the period of limitation.
Extended period of limitation - liability of a subcontractor to pay service tax - The High court concluded that the interpretation issue regarding subcontractor liability was unsettled until a later decision in 2019. Therefore, the respondent's actions were considered bona fide, and the failure to disclose the payment of service tax did not constitute suppression of facts. - Consequently, the court upheld the Tribunal's decision to remit the case back to the Commissioner without invoking the proviso to extend the period of limitation.
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