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 waiver application under Notification No. 21/2024-Central Tax was treated by the High Court as subject to a directory, not mandatory, three-month filing period because the notification used the word may. The rejection of the application solely on the ground of delay was therefore based on an erroneous interpretation of law. The Court quashed the rejection in FORM GST SPL-07 and directed the authority to reconsider the waiver application on merits in accordance with law, while keeping the show cause notice, summary notice and order in original in abeyance until that reconsideration.
A waiver application under Notification No. 21/2024-Central Tax was treated by the High Court as subject to a directory, not mandatory, three-month filing period because the notification used the word may. The rejection of the application solely on the ground of delay was therefore based on an erroneous interpretation of law. The Court quashed the rejection in FORM GST SPL-07 and directed the authority to reconsider the waiver application on merits in accordance with law, while keeping the show cause notice, summary notice and order in original in abeyance until that reconsideration.
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