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...
Blocking of the electronic credit ledger was challenged while parallel proceedings imposing tax, interest, fee and penalty under statutory tax provisions were pending; the petitioner's failure to disclose those proceedings in the writ was held material and counselling non-interference by the writ forum. Because the re-blocking related to an assessment and penalty demand of substantial amount and the statutory one year period since initial blocking had not expired, the court declined to interfere and dismissed the writ, leaving the statutory adjudication and credit availability/utilisation to proceed.
Blocking of the electronic credit ledger was challenged while parallel proceedings imposing tax, interest, fee and penalty under statutory tax provisions were pending; the petitioner's failure to disclose those proceedings in the writ was held material and counselling non-interference by the writ forum. Because the re-blocking related to an assessment and penalty demand of substantial amount and the statutory one year period since initial blocking had not expired, the court declined to interfere and dismissed the writ, leaving the statutory adjudication and credit availability/utilisation to proceed.
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