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...
IGST on imported goods falls within the customs assessment framework, so tariff classification, valuation, exemption and tax recovery are to be handled by customs authorities; GST officers cannot assess or recover such IGST, and the impugned notice on that issue was set aside. Cross-empowerment under GST operates only where the taxpayer is administratively allotted to the State and the officer is the proper officer; as the taxpayer was allotted to Central jurisdiction, the State tax officer lacked jurisdiction. A circular already struck down by a High Court was treated as inoperative nationwide without fresh invalidation. The notice also failed because it sought to cover multiple years in one show cause notice, and was set aside on that ground as well.
IGST on imported goods falls within the customs assessment framework, so tariff classification, valuation, exemption and tax recovery are to be handled by customs authorities; GST officers cannot assess or recover such IGST, and the impugned notice on that issue was set aside. Cross-empowerment under GST operates only where the taxpayer is administratively allotted to the State and the officer is the proper officer; as the taxpayer was allotted to Central jurisdiction, the State tax officer lacked jurisdiction. A circular already struck down by a High Court was treated as inoperative nationwide without fresh invalidation. The notice also failed because it sought to cover multiple years in one show cause notice, and was set aside on that ground as well.
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