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 set aside ex parte assessment order due to violation of natural justice principles. The order was passed without proper service of show cause notice, as notices were uploaded in an obscure portal column rendering them effectively unnoticed by the petitioner. The Deputy Commissioner's rejection of appeal on limitation grounds was overruled. The HC remanded the matter for fresh consideration, with the petitioner willing to pay 15% of disputed tax. The procedural defect in service of notice fundamentally invalidated the original assessment, ensuring the petitioner's right to fair hearing was reinstated.
HC set aside ex parte assessment order due to violation of natural justice principles. The order was passed without proper service of show cause notice, as notices were uploaded in an obscure portal column rendering them effectively unnoticed by the petitioner. The Deputy Commissioner's rejection of appeal on limitation grounds was overruled. The HC remanded the matter for fresh consideration, with the petitioner willing to pay 15% of disputed tax. The procedural defect in service of notice fundamentally invalidated the original assessment, ensuring the petitioner's right to fair hearing was reinstated.
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