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...
Attachment of Bank Account - Orders passed u/s 83(1) of the CGST Act - Period of limitation - The court acknowledges the statutory provision cited by the petitioner, confirming that orders under Section 83(1) of the CGST Act have a lifespan of one year and cease to operate thereafter. As the orders in question have expired, the court finds no basis for continuing the attachment. - While the respondents admit to issuing a fresh attachment order on 13.12.2023, the court does not delve into the validity of this specific order. Instead, it reserves the petitioner's right to challenge the fresh attachment order separately, leaving the question of its validity open for future adjudication.
Attachment of Bank Account - Orders passed u/s 83(1) of the CGST Act - Period of limitation - The court acknowledges the statutory provision cited by the petitioner, confirming that orders under Section 83(1) of the CGST Act have a lifespan of one year and cease to operate thereafter. As the orders in question have expired, the court finds no basis for continuing the attachment. - While the respondents admit to issuing a fresh attachment order on 13.12.2023, the court does not delve into the validity of this specific order. Instead, it reserves the petitioner's right to challenge the fresh attachment order separately, leaving the question of its validity open for future adjudication.
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