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...
Interplay between the Limitation Act and the UP GST Act concerns exclusion of limitation where a special statutory power to condone delay exists and where a bona fide rectification application is prosecuted with due diligence. The court reasons that a specific condonation power in the special Act operates to displace the general Section 5 principle, and that filing a timely application for rectification of an order puts the limitation to file an appeal in abeyance during its pendency; because the rectification application was filed within time and pursued in good faith, the pendency period is excluded and the subsequent appeal was held within limitation.
Interplay between the Limitation Act and the UP GST Act concerns exclusion of limitation where a special statutory power to condone delay exists and where a bona fide rectification application is prosecuted with due diligence. The court reasons that a specific condonation power in the special Act operates to displace the general Section 5 principle, and that filing a timely application for rectification of an order puts the limitation to file an appeal in abeyance during its pendency; because the rectification application was filed within time and pursued in good faith, the pendency period is excluded and the subsequent appeal was held within limitation.
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