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...
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Refund claims arising from an appellate order must be filed within one year from the date of that order under Section 27(1B)(b); the later filing here was therefore time-barred. The Tribunal also held that Section 26 did not apply because the case was not one of return or re-importation of exported goods, and in any event that provision contained its own time requirement, which was not met. The pending Revenue appeal did not alter the statutory limitation period. The rejection of the refund application on limitation grounds was upheld.
Refund claims arising from an appellate order must be filed within one year from the date of that order under Section 27(1B)(b); the later filing here was therefore time-barred. The Tribunal also held that Section 26 did not apply because the case was not one of return or re-importation of exported goods, and in any event that provision contained its own time requirement, which was not met. The pending Revenue appeal did not alter the statutory limitation period. The rejection of the refund application on limitation grounds was upheld.
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