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 HC quashed an order denying refund of unutilized Input Tax Credit for FY 2022-23 and Q1 of FY 2023-24. The respondent had rejected the refund claim because payments for exported services by petitioner's Delhi branch office were remitted to a bank account in Bangalore. Relying on Cable and Wireless Global India Private Limited, the Court held that mapping a Bangalore bank account after receiving remittances validates that services were exported by the Delhi branch office. The Court found the respondent's objection overly technical and unsustainable, ruling that remittance to a Bangalore bank account does not preclude refund eligibility. The petitioner's claim was remanded for reconsideration.
The HC quashed an order denying refund of unutilized Input Tax Credit for FY 2022-23 and Q1 of FY 2023-24. The respondent had rejected the refund claim because payments for exported services by petitioner's Delhi branch office were remitted to a bank account in Bangalore. Relying on Cable and Wireless Global India Private Limited, the Court held that mapping a Bangalore bank account after receiving remittances validates that services were exported by the Delhi branch office. The Court found the respondent's objection overly technical and unsustainable, ruling that remittance to a Bangalore bank account does not preclude refund eligibility. The petitioner's claim was remanded for reconsideration.
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