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...
Appellant filed refund claim which was initially rejected by original authority on grounds of ineligibility for exemption notification. Commissioner (Appeals) remanded matter to verify unjust enrichment after holding appellant eligible for exemption. Original authority determined duty element not passed on. Appellant ineligible for interest from date of original refund claim filing. For periods without show cause notice, refund claims filed later. Appellant eligible for interest on delayed refund payment from date after 3 months of Order-in-Appeal allowing exemption, as per Section 11BB of Central Excise Act.
Appellant filed refund claim which was initially rejected by original authority on grounds of ineligibility for exemption notification. Commissioner (Appeals) remanded matter to verify unjust enrichment after holding appellant eligible for exemption. Original authority determined duty element not passed on. Appellant ineligible for interest from date of original refund claim filing. For periods without show cause notice, refund claims filed later. Appellant eligible for interest on delayed refund payment from date after 3 months of Order-in-Appeal allowing exemption, as per Section 11BB of Central Excise Act.
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