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...
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The adhoc exemption order did not restrict the use of floodlights solely for World Cup matches; it aimed to uplift the stadium's infrastructure standards. The department erroneously assumed that World Cup matches were non-commercial, while one-day internationals were commercial. The exemption order made no such distinction. The show cause notice lacked factual or legal basis for alleging a violation of condition (ii). Regarding time limitation, the notice did not allege suppression of facts or intention to evade customs duty. The department issued the notice after collecting documents from the appellant, indicating no suppression. With a lapse of over 7 years, the demand was time-barred as the proviso to Section 28(1) was not applicable. The Appellate Tribunal set aside the impugned order and allowed the appeal.
The adhoc exemption order did not restrict the use of floodlights solely for World Cup matches; it aimed to uplift the stadium's infrastructure standards. The department erroneously assumed that World Cup matches were non-commercial, while one-day internationals were commercial. The exemption order made no such distinction. The show cause notice lacked factual or legal basis for alleging a violation of condition (ii). Regarding time limitation, the notice did not allege suppression of facts or intention to evade customs duty. The department issued the notice after collecting documents from the appellant, indicating no suppression. With a lapse of over 7 years, the demand was time-barred as the proviso to Section 28(1) was not applicable. The Appellate Tribunal set aside the impugned order and allowed the appeal.
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