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...
Reverse Charge (RCM) - Commissions paid to a foreign service provider - benefit of exemption under notification no. 18/2009-ST - non-discloser of detailed in the Shipping Bill - The CESTAT noted that the appellant's compliance with the procedural aspects of the notification, albeit delayed, was recognized. - The appellant successfully argued for the benefit of an exemption notification, although initially failing to meet some procedural requirements. The Tribunal's decision pivoted on the finding that there was no deliberate suppression of facts by the appellant, which is a necessary condition for extending the limitation period for tax demands.
Reverse Charge (RCM) - Commissions paid to a foreign service provider - benefit of exemption under notification no. 18/2009-ST - non-discloser of detailed in the Shipping Bill - The CESTAT noted that the appellant's compliance with the procedural aspects of the notification, albeit delayed, was recognized. - The appellant successfully argued for the benefit of an exemption notification, although initially failing to meet some procedural requirements. The Tribunal's decision pivoted on the finding that there was no deliberate suppression of facts by the appellant, which is a necessary condition for extending the limitation period for tax demands.
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