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...
Jurisdiction - power of Joint Commissioner (Investigation) Enforcement to exercise powers and functions of adjudicating authority - The State argues notifications should be read together, designating the Joint Commissioner as a proper officer for statewide jurisdiction. Respondent No. 1 argues the notification grants blanket powers statewide. The court finds the proper officer for adjudication must be designated, emphasizing jurisdictional limits in the notification. None of the notifications extend jurisdiction beyond the designated area. The court agrees with the petitioner's contention, restraining coercive actions and granting time for responses. - The matter is scheduled for further proceedings.
Jurisdiction - power of Joint Commissioner (Investigation) Enforcement to exercise powers and functions of adjudicating authority - The State argues notifications should be read together, designating the Joint Commissioner as a proper officer for statewide jurisdiction. Respondent No. 1 argues the notification grants blanket powers statewide. The court finds the proper officer for adjudication must be designated, emphasizing jurisdictional limits in the notification. None of the notifications extend jurisdiction beyond the designated area. The court agrees with the petitioner's contention, restraining coercive actions and granting time for responses. - The matter is scheduled for further proceedings.
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