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...
Challenged audit report and show cause notice were ordered reconsideration: the court found Defects 1-6 did not warrant confirmation of demand after verification of records and reconciliations, and observed no established suppression, misstatement or intent to evade tax. The respondent is directed to decide the issues on merits, provide opportunity of hearing and pass fresh orders pursuant to the audit report and show cause notice, preferably within three months of receipt. Interim relief had prevented final orders earlier; writ petitions disposed with remand for fresh consideration.
Challenged audit report and show cause notice were ordered reconsideration: the court found Defects 1-6 did not warrant confirmation of demand after verification of records and reconciliations, and observed no established suppression, misstatement or intent to evade tax. The respondent is directed to decide the issues on merits, provide opportunity of hearing and pass fresh orders pursuant to the audit report and show cause notice, preferably within three months of receipt. Interim relief had prevented final orders earlier; writ petitions disposed with remand for fresh consideration.
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