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...
Levy of interest u/s 50(3) - Wrong availment of Input of Tax Credit and reversal thereof - The court noted that the issue of levying interest under Section 50(3) of the Act for the wrongful availment and reversal of Input Tax Credit had been settled, as evidenced by the circular and various judgments cited. Additionally, the court considered the retrospective amendment in Section 50(3) of the Finance Act, 2022. - Matter remanded back to the adjudicating authority for fresh consideration in accordance with the law.
Levy of interest u/s 50(3) - Wrong availment of Input of Tax Credit and reversal thereof - The court noted that the issue of levying interest under Section 50(3) of the Act for the wrongful availment and reversal of Input Tax Credit had been settled, as evidenced by the circular and various judgments cited. Additionally, the court considered the retrospective amendment in Section 50(3) of the Finance Act, 2022. - Matter remanded back to the adjudicating authority for fresh consideration in accordance with the law.
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