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...
High Court found procedural infirmity where the adjudicating authority failed to record reasons for not considering material documents filed in response to assessment; the absence of reasoned consideration vitiated the order and the impugned adjudication was quashed. The authority was directed to revisit paragraph 10 and annexed bills of entry, afford the petitioners an opportunity of hearing, and pass a reasoned, speaking order within three months. Amounts debited from the petitioners' ledger may be considered for refund only conditionally and subject to the final outcome of the reconsideration; entitlement to refund was not decided on merits.
High Court found procedural infirmity where the adjudicating authority failed to record reasons for not considering material documents filed in response to assessment; the absence of reasoned consideration vitiated the order and the impugned adjudication was quashed. The authority was directed to revisit paragraph 10 and annexed bills of entry, afford the petitioners an opportunity of hearing, and pass a reasoned, speaking order within three months. Amounts debited from the petitioners' ledger may be considered for refund only conditionally and subject to the final outcome of the reconsideration; entitlement to refund was not decided on merits.
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