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...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Delay and laches barred relief where statutory limitation to challenge an administrative order had expired and the petitioner failed to prosecute an appeal after receiving notice; the COVID-19 stay of proceedings did not absolve the petitioner of the duty to monitor and list the appeal once stays were lifted, and negligent inaction after the stay ended was outcome-determinative. The High Court dismissed the petition for delay and laches, holding that interruption by the pandemic did not automatically revive an expired limitation where the appellant failed to pursue listing and follow up the appeal.
Delay and laches barred relief where statutory limitation to challenge an administrative order had expired and the petitioner failed to prosecute an appeal after receiving notice; the COVID-19 stay of proceedings did not absolve the petitioner of the duty to monitor and list the appeal once stays were lifted, and negligent inaction after the stay ended was outcome-determinative. The High Court dismissed the petition for delay and laches, holding that interruption by the pandemic did not automatically revive an expired limitation where the appellant failed to pursue listing and follow up the appeal.
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