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...
The High Court held that the petitioner was eligible to apply under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019, for resolving legacy tax disputes. The scheme aimed to liquidate legacy cases locked in litigation and provide amnesty for those who failed to correctly discharge their tax liability. The circular issued by the Central Board of Indirect Taxes and Customs clarified that in cases where tax was paid by utilizing input tax credit (ITC) and the matter is under dispute, the tax already paid shall be adjusted by the designated committee when determining the final payable amount under the scheme. The court found that the petitioner's case fell under this category, and the revenue was bound to adjust the ITC claimed by the petitioner, leaving the balance tax payable as nil. Consequently, the High Court directed the revenue authorities to issue the discharge certificate (SVLDRS-4) within four weeks.
The High Court held that the petitioner was eligible to apply under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019, for resolving legacy tax disputes. The scheme aimed to liquidate legacy cases locked in litigation and provide amnesty for those who failed to correctly discharge their tax liability. The circular issued by the Central Board of Indirect Taxes and Customs clarified that in cases where tax was paid by utilizing input tax credit (ITC) and the matter is under dispute, the tax already paid shall be adjusted by the designated committee when determining the final payable amount under the scheme. The court found that the petitioner's case fell under this category, and the revenue was bound to adjust the ITC claimed by the petitioner, leaving the balance tax payable as nil. Consequently, the High Court directed the revenue authorities to issue the discharge certificate (SVLDRS-4) within four weeks.
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