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...
Territorial Jurisdiction - seeking transfer of place of investigation - The petitioner cited inconvenience due to the distance between their headquarters in Thiruvananthapuram and the location of the investigation in Kasaragod. However, the court found no compelling reason to grant the transfer, noting that Kasaragod is within the boundaries of Kerala. Consequently, the court dismissed this plea. - On the matter of expediting the advance ruling application, the court noted that the application was relatively recent, filed in January 2024. Therefore, the court declined to intervene and compel the advance ruling authority to expedite the decision.
Territorial Jurisdiction - seeking transfer of place of investigation - The petitioner cited inconvenience due to the distance between their headquarters in Thiruvananthapuram and the location of the investigation in Kasaragod. However, the court found no compelling reason to grant the transfer, noting that Kasaragod is within the boundaries of Kerala. Consequently, the court dismissed this plea. - On the matter of expediting the advance ruling application, the court noted that the application was relatively recent, filed in January 2024. Therefore, the court declined to intervene and compel the advance ruling authority to expedite the decision.
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