Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Interference with an approved resolution plan under the Insolvency and Bankruptcy Code is confined to patent illegality, material irregularity, violation of mandatory law, or perversity, and a completed insolvency process cannot be reopened for mere dissatisfaction with claim treatment. The appellant's claim remained disputed and contingent throughout verification because of reciprocal contractual claims and counter-claims, so there was no admitted operational debt and no basis for invoking notice rights under Section 24(3)(c). Allegations of fraud, suppression, and procedural impropriety were unsupported, and the appellant showed no material prejudice affecting the resolution outcome. The appeal was dismissed, and the approved and implemented plan was left undisturbed.
Interference with an approved resolution plan under the Insolvency and Bankruptcy Code is confined to patent illegality, material irregularity, violation of mandatory law, or perversity, and a completed insolvency process cannot be reopened for mere dissatisfaction with claim treatment. The appellant's claim remained disputed and contingent throughout verification because of reciprocal contractual claims and counter-claims, so there was no admitted operational debt and no basis for invoking notice rights under Section 24(3)(c). Allegations of fraud, suppression, and procedural impropriety were unsupported, and the appellant showed no material prejudice affecting the resolution outcome. The appeal was dismissed, and the approved and implemented plan was left undisturbed.
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