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...
HC found systemic administrative deficiencies in tax proceedings where petitioner's adjournment request was not properly recorded due to software synchronization issues. The court identified twin factors of portal technical errors and human negligence. Recognizing the constitutional mandate of tax collection, HC directed mandatory involvement of CIT(Judicial) as a nodal officer in future tax petitions. The court quashed penalty and demand orders dated 21.12.2021 that were passed despite existing stay orders, emphasizing the need for a just and humane tax administration system that balances departmental responsibilities with assessee rights.
HC found systemic administrative deficiencies in tax proceedings where petitioner's adjournment request was not properly recorded due to software synchronization issues. The court identified twin factors of portal technical errors and human negligence. Recognizing the constitutional mandate of tax collection, HC directed mandatory involvement of CIT(Judicial) as a nodal officer in future tax petitions. The court quashed penalty and demand orders dated 21.12.2021 that were passed despite existing stay orders, emphasizing the need for a just and humane tax administration system that balances departmental responsibilities with assessee rights.
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