Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
A repeated Section 94 application by a personal guarantor was held not maintainable after an earlier fresh petition had already been dismissed on merits as time-barred. The tribunal treated the later filing as an identical attempt, noting suppression of the intervening dismissal and a pattern of repeated petitions aimed at securing interim moratorium and delaying recovery. It also rejected the argument that limitation began only from the possession notice, because a separate demand notice had already been issued to the guarantor earlier; the limitation finding based on that earlier notice was upheld. On these facts, the subsequent petition was held barred by res judicata, the abuse of process was found serious, and costs were imposed.
A repeated Section 94 application by a personal guarantor was held not maintainable after an earlier fresh petition had already been dismissed on merits as time-barred. The tribunal treated the later filing as an identical attempt, noting suppression of the intervening dismissal and a pattern of repeated petitions aimed at securing interim moratorium and delaying recovery. It also rejected the argument that limitation began only from the possession notice, because a separate demand notice had already been issued to the guarantor earlier; the limitation finding based on that earlier notice was upheld. On these facts, the subsequent petition was held barred by res judicata, the abuse of process was found serious, and costs were imposed.
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