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...
The Tribunal held that its earlier provisional release order under Section 110A was an interim arrangement balancing both sides and had already contemplated movement of goods from an SEZ unit to another SEZ unit, an EOU, or the DTA, as well as return-linked adjustment of the bank guarantee. The contingency later projected by the applicant was therefore not an apparent mistake on the record, and the plea of possible double duty did not justify rectification. Any operational difficulty in applying the release conditions could only be addressed by clarification, not by review through a ROM application. The rectification request was dismissed, while the Tribunal directed expeditious completion of the investigation.
The Tribunal held that its earlier provisional release order under Section 110A was an interim arrangement balancing both sides and had already contemplated movement of goods from an SEZ unit to another SEZ unit, an EOU, or the DTA, as well as return-linked adjustment of the bank guarantee. The contingency later projected by the applicant was therefore not an apparent mistake on the record, and the plea of possible double duty did not justify rectification. Any operational difficulty in applying the release conditions could only be addressed by clarification, not by review through a ROM application. The rectification request was dismissed, while the Tribunal directed expeditious completion of the investigation.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4817 
Join Channel 
