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...
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HC held that the blocking of petitioner's electronic credit ledger under Rule 86A of the CGST/KGST Rules was illegal and unsustainable. The Court found that no pre-decisional hearing was afforded and the impugned order lacked independent, cogent "reasons to believe," being based solely on enforcement reports amounting to impermissible borrowed satisfaction. Relying on binding precedent, HC ruled that these procedural and substantive deficiencies vitiated the exercise of power under Rule 86A. Consequently, the impugned order was quashed and respondents were directed to immediately unblock the petitioner's electronic credit ledger to enable filing of returns. The writ petition was allowed.
HC held that the blocking of petitioner's electronic credit ledger under Rule 86A of the CGST/KGST Rules was illegal and unsustainable. The Court found that no pre-decisional hearing was afforded and the impugned order lacked independent, cogent "reasons to believe," being based solely on enforcement reports amounting to impermissible borrowed satisfaction. Relying on binding precedent, HC ruled that these procedural and substantive deficiencies vitiated the exercise of power under Rule 86A. Consequently, the impugned order was quashed and respondents were directed to immediately unblock the petitioner's electronic credit ledger to enable filing of returns. The writ petition was allowed.
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