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...
Import restriction notifications become enforceable only upon publication in the prescribed e-Official Gazette, and the exact time of publication is legally significant where consignments have already arrived. Absent an enabling power for retrospective operation, subordinate legislation applies prospectively and cannot govern goods that landed before the notification came into force; those imports remain subject to the prior free regime. A separate challenge to the notification is not required when relief depends only on its non-application to the facts. On that basis, the goods were directed to be processed for release under the earlier legal position.
Import restriction notifications become enforceable only upon publication in the prescribed e-Official Gazette, and the exact time of publication is legally significant where consignments have already arrived. Absent an enabling power for retrospective operation, subordinate legislation applies prospectively and cannot govern goods that landed before the notification came into force; those imports remain subject to the prior free regime. A separate challenge to the notification is not required when relief depends only on its non-application to the facts. On that basis, the goods were directed to be processed for release under the earlier legal position.
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