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...
Adjustment of a refund against a disputed demand during pendency of statutory remedies was held unsustainable. Following coordinate Bench rulings, the HC quashed the refund adjustment, directed release of the refund with statutory interest, and restrained coercive recovery until the stay application is decided. The Court also requested expeditious disposal of the pending appeal before the CIT(A), and did not examine the merits of the underlying assessment dispute.
Adjustment of a refund against a disputed demand during pendency of statutory remedies was held unsustainable. Following coordinate Bench rulings, the HC quashed the refund adjustment, directed release of the refund with statutory interest, and restrained coercive recovery until the stay application is decided. The Court also requested expeditious disposal of the pending appeal before the CIT(A), and did not examine the merits of the underlying assessment dispute.
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