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...
Issuing a composite show-cause notice covering multiple tax periods under the CGST/KGST regime was treated as a jurisdictional defect, following the view that clubbing separate periods in one notice is illegal and impermissible. The impugned notice and the adjudication order founded on it were set aside. Liberty was reserved to the revenue to initiate fresh proceedings through separate show-cause notices for each tax period, and all other contentions were left open.
Issuing a composite show-cause notice covering multiple tax periods under the CGST/KGST regime was treated as a jurisdictional defect, following the view that clubbing separate periods in one notice is illegal and impermissible. The impugned notice and the adjudication order founded on it were set aside. Liberty was reserved to the revenue to initiate fresh proceedings through separate show-cause notices for each tax period, and all other contentions were left open.
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