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...
Limitation under the Insolvency and Bankruptcy Code is strict, time-bound and jurisdictional: an appeal must be filed in defect-free form within the statutory outer limit, and a defective presentation cannot be perfected at leisure. The procedural period for removing defects or seeking condonation of re-filing delay under the Supreme Court Rules cannot override the Code's timeline. Once the outer limit and the defect-cure period are both exhausted, the right of appeal stands extinguished and no condonation survives. The plea for a liberal approach, including the appellant's status as liquidator and reliance on Article 142, was rejected, and sufficient cause was not shown in any event.
Limitation under the Insolvency and Bankruptcy Code is strict, time-bound and jurisdictional: an appeal must be filed in defect-free form within the statutory outer limit, and a defective presentation cannot be perfected at leisure. The procedural period for removing defects or seeking condonation of re-filing delay under the Supreme Court Rules cannot override the Code's timeline. Once the outer limit and the defect-cure period are both exhausted, the right of appeal stands extinguished and no condonation survives. The plea for a liberal approach, including the appellant's status as liquidator and reliance on Article 142, was rejected, and sufficient cause was not shown in any event.
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