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...
A writ challenge to a notice initiating revision under Section 108 was held premature because no final revisional order had yet been passed. The High Court left open the petitioner's objections on jurisdiction and maintainability to be raised before the revisional authority and declined interference at the threshold. At the same time, it protected the petitioner by directing conditional release of the goods pending revision, subject to an additional deposit, filing of an affidavit undertaking to abide by the revisional order, and participation in the revisional proceedings. The writ petition was disposed of without examining the merits of the revision challenge.
A writ challenge to a notice initiating revision under Section 108 was held premature because no final revisional order had yet been passed. The High Court left open the petitioner's objections on jurisdiction and maintainability to be raised before the revisional authority and declined interference at the threshold. At the same time, it protected the petitioner by directing conditional release of the goods pending revision, subject to an additional deposit, filing of an affidavit undertaking to abide by the revisional order, and participation in the revisional proceedings. The writ petition was disposed of without examining the merits of the revision challenge.
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