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...
Inadvertence claim untenable, delay in rectifying alleged error reflects absence of inadvertence. Petitioner withdrew higher value complaint, pursued lower value complaint, then approached mediation without realizing inadvertence. Petitioner revived execution petition for arbitral award recovery instead of complaint cases, indicating deliberate choice. Application u/s 362 CrPC for recall filed belatedly after six months, dismissed by magistrate. Conduct inconsistent with inadvertence claim. Petition dismissed for lack of merit.
Inadvertence claim untenable, delay in rectifying alleged error reflects absence of inadvertence. Petitioner withdrew higher value complaint, pursued lower value complaint, then approached mediation without realizing inadvertence. Petitioner revived execution petition for arbitral award recovery instead of complaint cases, indicating deliberate choice. Application u/s 362 CrPC for recall filed belatedly after six months, dismissed by magistrate. Conduct inconsistent with inadvertence claim. Petition dismissed for lack of merit.
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