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...
Wrongful retention of seized Kisan Vikas Patras and Indira Vikas Patras after deposit of the settlement amount justified compensatory interest for loss of opportunity cost, but only from the date the settlement amount was paid until actual release. Because the Settlement Commission's direction to release the instruments after deposit had attained finality, no interest was payable for any earlier period. The amount awarded was treated as restitution for unjustified deprivation, not statutory refund interest, and the Court also allowed further simple interest at 4% per annum on that compensatory amount until payment.
Wrongful retention of seized Kisan Vikas Patras and Indira Vikas Patras after deposit of the settlement amount justified compensatory interest for loss of opportunity cost, but only from the date the settlement amount was paid until actual release. Because the Settlement Commission's direction to release the instruments after deposit had attained finality, no interest was payable for any earlier period. The amount awarded was treated as restitution for unjustified deprivation, not statutory refund interest, and the Court also allowed further simple interest at 4% per annum on that compensatory amount until payment.
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