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...
Co-operative housing society providing residential flats to members does not constitute taxable service under "construction of residential complex" due to doctrine of mutuality. Society and members not separate entities, hence no service provider-recipient relationship exists. Activity falls under "Club or Association Service". Demand unsustainable as per Supreme Court's decision in Calcutta Club case covering pre and post-negative list regime periods. Even if time-barred, no suppression of facts attributable to society given interpretational issues involved. Demand unsustainable on grounds of doctrine of mutuality and time bar.
Co-operative housing society providing residential flats to members does not constitute taxable service under "construction of residential complex" due to doctrine of mutuality. Society and members not separate entities, hence no service provider-recipient relationship exists. Activity falls under "Club or Association Service". Demand unsustainable as per Supreme Court's decision in Calcutta Club case covering pre and post-negative list regime periods. Even if time-barred, no suppression of facts attributable to society given interpretational issues involved. Demand unsustainable on grounds of doctrine of mutuality and time bar.
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