Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
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...
Tax liability arising during CIRP was not extinguished by the approved resolution plan, because the plan showed awareness of pending tax compliances, the NCLT did not grant a blanket waiver of statutory dues, and reliefs were left to the appropriate forum. The Court held that the clean slate principle and the Supreme Court rulings in Essar Steel and Ghanashyam Mishra applied to pre-CIRP dues, not liabilities incurred during CIRP; the reassessment challenge therefore failed. On delayed return filing and carry forward of losses, the petitioner was required to seek condonation under the statutory mechanism, including CBDT action under section 119(2)(b), and could not obtain such relief in writ proceedings. The writ petition was dismissed.
Tax liability arising during CIRP was not extinguished by the approved resolution plan, because the plan showed awareness of pending tax compliances, the NCLT did not grant a blanket waiver of statutory dues, and reliefs were left to the appropriate forum. The Court held that the clean slate principle and the Supreme Court rulings in Essar Steel and Ghanashyam Mishra applied to pre-CIRP dues, not liabilities incurred during CIRP; the reassessment challenge therefore failed. On delayed return filing and carry forward of losses, the petitioner was required to seek condonation under the statutory mechanism, including CBDT action under section 119(2)(b), and could not obtain such relief in writ proceedings. The writ petition was dismissed.
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