Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
SC held that the Limitation Act applies comprehensively to recovery proceedings. Section 18 permits limitation period extension when liability is acknowledged, particularly where payment time has not yet matured. The respondents' technical objections were deemed dilatory, as they were aware of previous judicial determinations. The High Court's order was set aside, with writ petitions to be restored and heard after disposal of pending intra-court appeals. The limitation period for recovery proceedings was effectively extended due to respondents' liability acknowledgment, enabling the appellant to pursue legal remedies within prescribed timelines.
SC held that the Limitation Act applies comprehensively to recovery proceedings. Section 18 permits limitation period extension when liability is acknowledged, particularly where payment time has not yet matured. The respondents' technical objections were deemed dilatory, as they were aware of previous judicial determinations. The High Court's order was set aside, with writ petitions to be restored and heard after disposal of pending intra-court appeals. The limitation period for recovery proceedings was effectively extended due to respondents' liability acknowledgment, enabling the appellant to pursue legal remedies within prescribed timelines.
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