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...
IBC prevails over electricity law where pre-CIRP dues were not included in an approved resolution plan, because Sections 31 and 238 bind all stakeholders and give the plan finality on a clean slate basis. The Court held that statutory electricity authorities are also bound by the resolution plan, and pre-resolution claims not filed during CIRP stand extinguished by operation of law. Public announcement of CIRP was sufficient notice; separate individual service was not required. The impugned demand notices were quashed insofar as they sought recovery of pre-CIRP dues, while liberty was reserved to raise fresh demands only for lawful post-resolution liability.
IBC prevails over electricity law where pre-CIRP dues were not included in an approved resolution plan, because Sections 31 and 238 bind all stakeholders and give the plan finality on a clean slate basis. The Court held that statutory electricity authorities are also bound by the resolution plan, and pre-resolution claims not filed during CIRP stand extinguished by operation of law. Public announcement of CIRP was sufficient notice; separate individual service was not required. The impugned demand notices were quashed insofar as they sought recovery of pre-CIRP dues, while liberty was reserved to raise fresh demands only for lawful post-resolution liability.
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