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...
Validity of Charge memo issued to CIT(A) - The case involved a challenge to an order issued by the Central Administrative Tribunal, which had quashed a charge memo against the respondent, a former Commissioner of Income Tax (Appeals). The petitioners alleged that the respondent had wrongly decided five appeals during his tenure, prompting the issuance of the charge memo in 2014. However, the High Court found that the delay of over ten years in issuing the charge memo was unjustified and could prejudice the respondent's defense. Despite arguments regarding the applicability of previous court decisions and the nature of the respondent's duties, the Court upheld the Tribunal's decision and dismissed the writ petition.
Validity of Charge memo issued to CIT(A) - The case involved a challenge to an order issued by the Central Administrative Tribunal, which had quashed a charge memo against the respondent, a former Commissioner of Income Tax (Appeals). The petitioners alleged that the respondent had wrongly decided five appeals during his tenure, prompting the issuance of the charge memo in 2014. However, the High Court found that the delay of over ten years in issuing the charge memo was unjustified and could prejudice the respondent's defense. Despite arguments regarding the applicability of previous court decisions and the nature of the respondent's duties, the Court upheld the Tribunal's decision and dismissed the writ petition.
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