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...
Non-speaking assessment orders that do not address taxpayer submissions violate the principles of natural justice; the impugned orders confirming liability and referring to interest and penalty without reasoned findings were quashed and set aside. The respondents are directed to issue fresh show-cause notices, grant a personal hearing, and pass detailed, reasoned speaking orders expeditiously (preferably within one month of service). The court found mechanical adjudication caused prejudice and remanded the matter for fresh adjudication to cure the procedural defect.
Non-speaking assessment orders that do not address taxpayer submissions violate the principles of natural justice; the impugned orders confirming liability and referring to interest and penalty without reasoned findings were quashed and set aside. The respondents are directed to issue fresh show-cause notices, grant a personal hearing, and pass detailed, reasoned speaking orders expeditiously (preferably within one month of service). The court found mechanical adjudication caused prejudice and remanded the matter for fresh adjudication to cure the procedural defect.
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