Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
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The HC upheld the impugned judgment in full and dismissed the appeal. The court found the revocation of the IPLOI (as amended) and subsequent invocation of the unconditional bank guarantee valid under the contractual terms: the Appellants defaulted, Clause 11 and the Addendum authorized termination and invocation, and the IPLOI prevailed over any RFP discrepancy. The Section 7 application filed by Respondent No.1 was not admitted before revocation and was ultimately dismissed as infructuous, so no actionable fraud was attributable to Respondent No.1; allegations of fraud were unpleaded and unproved. The court declined to restrain invocation of the unconditional BG absent egregious fraud or irretrievable injustice.
The HC upheld the impugned judgment in full and dismissed the appeal. The court found the revocation of the IPLOI (as amended) and subsequent invocation of the unconditional bank guarantee valid under the contractual terms: the Appellants defaulted, Clause 11 and the Addendum authorized termination and invocation, and the IPLOI prevailed over any RFP discrepancy. The Section 7 application filed by Respondent No.1 was not admitted before revocation and was ultimately dismissed as infructuous, so no actionable fraud was attributable to Respondent No.1; allegations of fraud were unpleaded and unproved. The court declined to restrain invocation of the unconditional BG absent egregious fraud or irretrievable injustice.
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