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...
An ex parte rejection of a GST refund claim without a deficiency memo and without affording a hearing was procedurally invalid, so the refund application had to be reconsidered in the manner prescribed by the rules. The Court noted that a subsequent refund application had been filed, a deficiency memo had been issued on that application, and it was required to be taken to its logical conclusion rather than denied on a pedantic view. The designated officer was directed to decide the refund application and related applications afresh under Rules 90 and 92, uninfluenced by the earlier rejection order or the appellate dismissal on limitation, with merits left open.
An ex parte rejection of a GST refund claim without a deficiency memo and without affording a hearing was procedurally invalid, so the refund application had to be reconsidered in the manner prescribed by the rules. The Court noted that a subsequent refund application had been filed, a deficiency memo had been issued on that application, and it was required to be taken to its logical conclusion rather than denied on a pedantic view. The designated officer was directed to decide the refund application and related applications afresh under Rules 90 and 92, uninfluenced by the earlier rejection order or the appellate dismissal on limitation, with merits left open.
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