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...
Impugned order suffered from lack of reasoning regarding variation in service tax estimate between declarant/petitioner and designated authority. 50% of demand confirmed, with petitioner submitting lessee paid said amount eligible for set-off under Sabka Vishwas Scheme. Court held petitioner liable for service tax on immovable property rentals from 2007 under Finance Act, 1994, though lessees unsuccessfully challenged levy before various High Courts. Supreme Court ordered lessees to pay 50% property tax despite not being liable under Finance Act. Impugned order passed by two officers, one not hearing petitioner, violating natural justice. Circular on Sabka Vishwas Scheme unclear on appropriating lessee's deposited amount towards declarant's liability and refund mechanism. Court quashed impugned order, remitting case for fresh orders on merits due to element of doubt.
Impugned order suffered from lack of reasoning regarding variation in service tax estimate between declarant/petitioner and designated authority. 50% of demand confirmed, with petitioner submitting lessee paid said amount eligible for set-off under Sabka Vishwas Scheme. Court held petitioner liable for service tax on immovable property rentals from 2007 under Finance Act, 1994, though lessees unsuccessfully challenged levy before various High Courts. Supreme Court ordered lessees to pay 50% property tax despite not being liable under Finance Act. Impugned order passed by two officers, one not hearing petitioner, violating natural justice. Circular on Sabka Vishwas Scheme unclear on appropriating lessee's deposited amount towards declarant's liability and refund mechanism. Court quashed impugned order, remitting case for fresh orders on merits due to element of doubt.
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