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...
Clubbing multiple tax periods/financial years (2019-20 to 2021-22) into a single composite show cause notice under ss. 73/74 of the CGST/KGST Act for reversal of input tax credit was held invalid, as such bunching had already been declared illegal in an earlier binding decision. Since the proceedings were founded on an impermissible consolidated notice, the consequential adjudication order could not survive. The composite show cause notice and the ensuing order were quashed, and the respondent was directed to drop the proceedings; the petition was allowed. - HC
Clubbing multiple tax periods/financial years (2019-20 to 2021-22) into a single composite show cause notice under ss. 73/74 of the CGST/KGST Act for reversal of input tax credit was held invalid, as such bunching had already been declared illegal in an earlier binding decision. Since the proceedings were founded on an impermissible consolidated notice, the consequential adjudication order could not survive. The composite show cause notice and the ensuing order were quashed, and the respondent was directed to drop the proceedings; the petition was allowed. - HC
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