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...
Writ challenges to show-cause and pre-intimation notices blocking input tax credit were held premature where the disputes turned on individual facts and the CGST Act and Rules provided a complete code. The Court declined to examine the merits of the proposed ITC action or the constitutional validity of Section 16(2)(c) at this stage, finding that such issues required case-specific adjudication after replies and objections were considered. Petitioners were permitted to respond to the notices, and the statutory authorities were directed to decide the matters in accordance with law, while keeping all contentions open.
Writ challenges to show-cause and pre-intimation notices blocking input tax credit were held premature where the disputes turned on individual facts and the CGST Act and Rules provided a complete code. The Court declined to examine the merits of the proposed ITC action or the constitutional validity of Section 16(2)(c) at this stage, finding that such issues required case-specific adjudication after replies and objections were considered. Petitioners were permitted to respond to the notices, and the statutory authorities were directed to decide the matters in accordance with law, while keeping all contentions open.
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