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...
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Res judicata barred the challenge because it repeated issues already decided against the successful resolution applicant, and the liquidation direction merely carried forward earlier final orders aimed at closure under the insolvency framework. The tribunal held that a post-reservation application for a one-time payment proposal did not create any right to rehearing, and the unilateral restructuring plea was a belated attempt to obstruct liquidation. It also held that regulatory approvals were the applicant's own responsibility under the approved plan; mere pendency of approval requests and repeated non-payment could not justify indefinite delay. Prolonged non-implementation, value erosion and lack of credible performance therefore justified liquidation, and the appeal was dismissed with costs.
Res judicata barred the challenge because it repeated issues already decided against the successful resolution applicant, and the liquidation direction merely carried forward earlier final orders aimed at closure under the insolvency framework. The tribunal held that a post-reservation application for a one-time payment proposal did not create any right to rehearing, and the unilateral restructuring plea was a belated attempt to obstruct liquidation. It also held that regulatory approvals were the applicant's own responsibility under the approved plan; mere pendency of approval requests and repeated non-payment could not justify indefinite delay. Prolonged non-implementation, value erosion and lack of credible performance therefore justified liquidation, and the appeal was dismissed with costs.
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