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...
Impleading of the Jurisdictional Commissioner as another respondent alongwith Commissioner (Adjudication) - The Tribunal examined Rule 12 of the CESTAT Procedure Rules, 1982, which states who may be joined as respondents. It was clarified that the Principal Commissioner or Commissioner concerned should be impleaded as the respondent. The Tribunal interpreted the term "concerned" to mean the Commissionerate issuing the show cause notice, making the Principal Commissioner or Commissioner of that Commissionerate the relevant party to the case. - The Tribunal found that there was no restriction on impleading more than one respondent in appeals filed, especially in cases involving multiple jurisdictions.
Impleading of the Jurisdictional Commissioner as another respondent alongwith Commissioner (Adjudication) - The Tribunal examined Rule 12 of the CESTAT Procedure Rules, 1982, which states who may be joined as respondents. It was clarified that the Principal Commissioner or Commissioner concerned should be impleaded as the respondent. The Tribunal interpreted the term "concerned" to mean the Commissionerate issuing the show cause notice, making the Principal Commissioner or Commissioner of that Commissionerate the relevant party to the case. - The Tribunal found that there was no restriction on impleading more than one respondent in appeals filed, especially in cases involving multiple jurisdictions.
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