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...
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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