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...
HC set aside assessment orders due to procedural deficiencies in tax evaluation. Authority failed to consider complete financial details, particularly regarding tax payments on scrap sales and battery sales, violating natural justice principles. Petitioner presented detailed break-up of tax payments for the first time before HC, which was not previously examined during assessment. Court determined petitioner deserved opportunity to present case with new materials. Matter remanded to original authority for fresh consideration, ensuring proper evaluation of all financial documentation and compliance with procedural fairness requirements.
HC set aside assessment orders due to procedural deficiencies in tax evaluation. Authority failed to consider complete financial details, particularly regarding tax payments on scrap sales and battery sales, violating natural justice principles. Petitioner presented detailed break-up of tax payments for the first time before HC, which was not previously examined during assessment. Court determined petitioner deserved opportunity to present case with new materials. Matter remanded to original authority for fresh consideration, ensuring proper evaluation of all financial documentation and compliance with procedural fairness requirements.
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