Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
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...
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Contractual reimbursement of GST on gas-transmission charges depends on a plausible reading of the Gas Sale Agreement, and an arbitral tribunal's construction is not displaced merely because another interpretation is possible. The notes state that reimbursement could not be sustained without admissible evidence linking GST-deposit receipts to the relevant gas transactions; reliance on unproved documents despite an unresolved objection offends natural justice. They also distinguish waiver from estoppel: waiver requires intentional relinquishment of a known right, while estoppel requires representation, reliance and alteration of position. Payment of prior invoices under a clause requiring payment before claims may preserve supply and does not, by itself, bar recurring invoice-based claims.
Contractual reimbursement of GST on gas-transmission charges depends on a plausible reading of the Gas Sale Agreement, and an arbitral tribunal's construction is not displaced merely because another interpretation is possible. The notes state that reimbursement could not be sustained without admissible evidence linking GST-deposit receipts to the relevant gas transactions; reliance on unproved documents despite an unresolved objection offends natural justice. They also distinguish waiver from estoppel: waiver requires intentional relinquishment of a known right, while estoppel requires representation, reliance and alteration of position. Payment of prior invoices under a clause requiring payment before claims may preserve supply and does not, by itself, bar recurring invoice-based claims.
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