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...
Transfer of pending winding up proceedings under the statutory transfer scheme can be ordered even without a party application, because Section 434(1)(c) requires assessment of the stage of liquidation and whether it has become irreversible or irretrievable. On the facts, only possession of assets had been taken and the immovable properties remained unsold, so liquidation had not crossed that stage. The transfer order was therefore a valid exercise of jurisdiction and the challenge failed.
Transfer of pending winding up proceedings under the statutory transfer scheme can be ordered even without a party application, because Section 434(1)(c) requires assessment of the stage of liquidation and whether it has become irreversible or irretrievable. On the facts, only possession of assets had been taken and the immovable properties remained unsold, so liquidation had not crossed that stage. The transfer order was therefore a valid exercise of jurisdiction and the challenge failed.
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