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...
Shipping bill amendments were allowed under Section 149 to correct the reward column from "No" to "Yes" for MEIS claims, as the wrong entry was treated as a curable procedural lapse and not a bar to substantive export incentive. The Tribunal held that delay in seeking amendment must be assessed on the facts of each case, and the notification-based time limit could be extended where the competent customs authority was satisfied with the explanation. The preliminary forum objection was rejected because the matter had long remained before a Single Member without objection from Revenue. Consequential relief was granted.
Shipping bill amendments were allowed under Section 149 to correct the reward column from "No" to "Yes" for MEIS claims, as the wrong entry was treated as a curable procedural lapse and not a bar to substantive export incentive. The Tribunal held that delay in seeking amendment must be assessed on the facts of each case, and the notification-based time limit could be extended where the competent customs authority was satisfied with the explanation. The preliminary forum objection was rejected because the matter had long remained before a Single Member without objection from Revenue. Consequential relief was granted.
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