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...
Rejection of refund on the ground of delay - time limitation - The High Court examined the timeline of the refund applications in light of the Covid-19 pandemic's impact on statutory limitations. It noted that the applications were indeed filed within the extended timeframe provided by the Government Notification No.13 of 2022, which suspended limitations from February 15, 2020, to February 28, 2022. The Court cited a precedent case, Gamma Gaana Ltd. vs. Union of India, to reinforce this interpretation. - The Court directed the authority to process the refund applications without objections regarding delay.
Rejection of refund on the ground of delay - time limitation - The High Court examined the timeline of the refund applications in light of the Covid-19 pandemic's impact on statutory limitations. It noted that the applications were indeed filed within the extended timeframe provided by the Government Notification No.13 of 2022, which suspended limitations from February 15, 2020, to February 28, 2022. The Court cited a precedent case, Gamma Gaana Ltd. vs. Union of India, to reinforce this interpretation. - The Court directed the authority to process the refund applications without objections regarding delay.
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