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...
Regarding processing of manual refund application, it is held that when genuine issues arise, the Department should adopt a liberal approach, particularly considering that no party would intentionally delay or fail to file refund application in the portal when substantial refund amount is due. The Department should avoid unwarranted litigation on such issues and make the system more assessee-friendly, fostering Revenue's interest in tax collection. In the given case, technicalities should not impede the assessee. The petition is disposed of.
Regarding processing of manual refund application, it is held that when genuine issues arise, the Department should adopt a liberal approach, particularly considering that no party would intentionally delay or fail to file refund application in the portal when substantial refund amount is due. The Department should avoid unwarranted litigation on such issues and make the system more assessee-friendly, fostering Revenue's interest in tax collection. In the given case, technicalities should not impede the assessee. The petition is disposed of.
Note: It is a system-generated summary and is for quick reference only.
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