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...
The HC refused to quash an ex parte GST adjudication order where the assessee had neither replied to the show cause notice nor filed a statutory appeal within limitation. It accepted that, after the portal upgrade on 16.01.2024, notices uploaded under the "Additional Notices and Orders" tab were visible, so earlier decisions on non-visibility were inapplicable. The writ petition was therefore not entertained on the alleged notice defect, the Section 107 appellate remedy being the ordinary course. However, because the appeal period had expired during pendency of the writ, the Court granted a conditional opportunity to file a reply and seek reconsideration upon deposit of 50% of the tax and penalty, excluding interest.
The HC refused to quash an ex parte GST adjudication order where the assessee had neither replied to the show cause notice nor filed a statutory appeal within limitation. It accepted that, after the portal upgrade on 16.01.2024, notices uploaded under the "Additional Notices and Orders" tab were visible, so earlier decisions on non-visibility were inapplicable. The writ petition was therefore not entertained on the alleged notice defect, the Section 107 appellate remedy being the ordinary course. However, because the appeal period had expired during pendency of the writ, the Court granted a conditional opportunity to file a reply and seek reconsideration upon deposit of 50% of the tax and penalty, excluding interest.
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