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...
Validity of provisional attachment of the Petitioner’s bank account - Despite the petitioner's contentions, the High court determined that substantial material existed for the Commissioner to form an opinion in favor of the attachment. The court emphasized that the petitioner failed to confront the department with sufficient evidence against the action under Section 83 of the CGST Act. Furthermore, the court noted the issuance of a Show Cause Notice with abundant material supporting a tax demand against the petitioner. Considering these factors, the court rejected the petitioner's challenge to the provisional attachment.
Validity of provisional attachment of the Petitioner’s bank account - Despite the petitioner's contentions, the High court determined that substantial material existed for the Commissioner to form an opinion in favor of the attachment. The court emphasized that the petitioner failed to confront the department with sufficient evidence against the action under Section 83 of the CGST Act. Furthermore, the court noted the issuance of a Show Cause Notice with abundant material supporting a tax demand against the petitioner. Considering these factors, the court rejected the petitioner's challenge to the provisional attachment.
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