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...
Application maintainability was questioned where the applicant initially failed to produce purchase and sales invoices and product brochure; the appellate power to confirm or modify an advance ruling exists but no merits determination was possible on the record. The applicant subsequently furnished invoices and offered further documents at hearing; those materials require factual verification and assessment for relevance. The appellate body set aside the impugned non maintainability ruling and remanded the matter to the Advance Ruling Authority for fresh examination and decision in light of the newly produced records.
Application maintainability was questioned where the applicant initially failed to produce purchase and sales invoices and product brochure; the appellate power to confirm or modify an advance ruling exists but no merits determination was possible on the record. The applicant subsequently furnished invoices and offered further documents at hearing; those materials require factual verification and assessment for relevance. The appellate body set aside the impugned non maintainability ruling and remanded the matter to the Advance Ruling Authority for fresh examination and decision in light of the newly produced records.
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