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Transfer-pricing benchmarking and capital-receipt principles sustained taxpayer relief, while unsupported property-advance write-offs remained disallo...
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An insolvency appeal under section 61 must be filed from pronouncement of the original order within the statutory outer limit; a clerical rectification of the pronouncement date, without substantive change, does not restart limitation. The moratorium-period exclusion does not apply to such appeals, and administrative lapses cannot extend time. For a section 9 application, Article 137 runs from default, while a valid acknowledgment must be written, proved and unequivocally admit subsisting liability before limitation expires. Undated, unproved and inconsistent balance confirmations did not satisfy that standard. Pre-demand correspondence also showed a genuine, continuing dispute over accounts and set-offs, independently making the operational creditor's application not maintainable.
An insolvency appeal under section 61 must be filed from pronouncement of the original order within the statutory outer limit; a clerical rectification of the pronouncement date, without substantive change, does not restart limitation. The moratorium-period exclusion does not apply to such appeals, and administrative lapses cannot extend time. For a section 9 application, Article 137 runs from default, while a valid acknowledgment must be written, proved and unequivocally admit subsisting liability before limitation expires. Undated, unproved and inconsistent balance confirmations did not satisfy that standard. Pre-demand correspondence also showed a genuine, continuing dispute over accounts and set-offs, independently making the operational creditor's application not maintainable.
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