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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Extraordinary delay in filing revisions was not condoned because the explanation of wrong legal advice and bona fide misconception was contrary to the record and did not satisfy "sufficient cause"; the revisions against conviction were dismissed as time-barred. The settlement agreement did not extinguish the pending Section 138 complaints because withdrawal was expressly conditional on full payment, and default kept the complainant's right to proceed alive; quashing was refused. Civil execution and criminal cheque-dishonour proceedings were held to operate in distinct fields, so double jeopardy did not apply and probation was declined. Earlier and later payments were credited while computing liability, leading only to a limited reduction in fine.
Extraordinary delay in filing revisions was not condoned because the explanation of wrong legal advice and bona fide misconception was contrary to the record and did not satisfy "sufficient cause"; the revisions against conviction were dismissed as time-barred. The settlement agreement did not extinguish the pending Section 138 complaints because withdrawal was expressly conditional on full payment, and default kept the complainant's right to proceed alive; quashing was refused. Civil execution and criminal cheque-dishonour proceedings were held to operate in distinct fields, so double jeopardy did not apply and probation was declined. Earlier and later payments were credited while computing liability, leading only to a limited reduction in fine.
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