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...
Interpretation of the Interest Equalisation Scheme and DGFT clarification on whether interest subvention reduces from 5% to 3% from 1 October 2021 for export credit whose tenor extends beyond 30 September 2021 was decided by holding that the phrase "only for the period upto 30th September, 2021" governs benefits to be passed on by the bank, not the credit tenor, and the DGFT clarification confirms tenor is irrelevant. As the bank had discounted export bills and upfront passed the 5% benefit knowing the credit ran beyond 30 September 2021, it could not later claw back the differential; recovery from the exporter was wrongful. Refund of the recovered amount with 8% interest from the recovery date and costs was decreed. - HC
Interpretation of the Interest Equalisation Scheme and DGFT clarification on whether interest subvention reduces from 5% to 3% from 1 October 2021 for export credit whose tenor extends beyond 30 September 2021 was decided by holding that the phrase "only for the period upto 30th September, 2021" governs benefits to be passed on by the bank, not the credit tenor, and the DGFT clarification confirms tenor is irrelevant. As the bank had discounted export bills and upfront passed the 5% benefit knowing the credit ran beyond 30 September 2021, it could not later claw back the differential; recovery from the exporter was wrongful. Refund of the recovered amount with 8% interest from the recovery date and costs was decreed. - HC
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