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...
Penalty imposed u/r 26 of Central Excise Rules 2002 set aside due to violation of principles of natural justice and lack of evidence. Department's case based solely on statements without allowing cross-examination. Rule 26 penalty requires involvement in clearance of goods liable for confiscation, which was not established against the appellants. Imposition of penalty u/r 26 unsustainable as appellants not involved in activities attracting Rule 26. Penalty on directors set aside as one director not concerned with activities at the relevant plant. Appeals of three appellants allowed, fourth appellant's appeal partly allowed.
Penalty imposed u/r 26 of Central Excise Rules 2002 set aside due to violation of principles of natural justice and lack of evidence. Department's case based solely on statements without allowing cross-examination. Rule 26 penalty requires involvement in clearance of goods liable for confiscation, which was not established against the appellants. Imposition of penalty u/r 26 unsustainable as appellants not involved in activities attracting Rule 26. Penalty on directors set aside as one director not concerned with activities at the relevant plant. Appeals of three appellants allowed, fourth appellant's appeal partly allowed.
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