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...
Petitioners challenged the re-attachment of their third account by the Department after the initial attachment expired by operation of law u/s 83(2) of the Act. The Court held that once the attachment expires, the Department lacks jurisdiction to re-attach the same account. Consequently, the Court directed lifting of the attachment made on 30.08.2024 on petitioners' third account and ordered the account to be defreezed, as the re-attachment was without legal authority.
Petitioners challenged the re-attachment of their third account by the Department after the initial attachment expired by operation of law u/s 83(2) of the Act. The Court held that once the attachment expires, the Department lacks jurisdiction to re-attach the same account. Consequently, the Court directed lifting of the attachment made on 30.08.2024 on petitioners' third account and ordered the account to be defreezed, as the re-attachment was without legal authority.
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