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...
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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