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...
Ex parte adjudication orders were set aside because the petitioner had not been given an effective opportunity to reply to the show cause notice. The HC accepted that the petitioner could place material before the authority, including the objection that two orders had been passed for the same tax period on the same ITC mismatch ground. The matter was remitted for fresh consideration from the stage of reply to the show cause notice, with all merits contentions left open, subject to payment of 10% of the tax demand under the specified annexures.
Ex parte adjudication orders were set aside because the petitioner had not been given an effective opportunity to reply to the show cause notice. The HC accepted that the petitioner could place material before the authority, including the objection that two orders had been passed for the same tax period on the same ITC mismatch ground. The matter was remitted for fresh consideration from the stage of reply to the show cause notice, with all merits contentions left open, subject to payment of 10% of the tax demand under the specified annexures.
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