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 granted ad-interim relief to petitioners challenging retrospective application of penalty under Section 122(1A). The court found a prima facie case exists, noting the statutory provision was enacted on 1 January 2021 but sought to impose penalties for period prior to enforcement (July 2017 to December 2020). The court's interim order suggests substantial merit in petitioners' arguments, referencing a prior judicial precedent. Balance of convenience favors petitioners, indicating potential procedural irregularity in retrospective penalty imposition. Petition disposed with interim relief granted.
HC granted ad-interim relief to petitioners challenging retrospective application of penalty under Section 122(1A). The court found a prima facie case exists, noting the statutory provision was enacted on 1 January 2021 but sought to impose penalties for period prior to enforcement (July 2017 to December 2020). The court's interim order suggests substantial merit in petitioners' arguments, referencing a prior judicial precedent. Balance of convenience favors petitioners, indicating potential procedural irregularity in retrospective penalty imposition. Petition disposed with interim relief granted.
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