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...
Section 95(4)(a) of the Insolvency and Bankruptcy Code was treated as a completeness requirement for personal guarantor insolvency applications, not a rigid jurisdictional bar. Where liability was admitted through guarantee deeds, compromise terms and earlier judicial proceedings, the Appellate Tribunal held that the statutory purpose of disclosing debt was already satisfied and no further elaborate narration was necessary. A procedural objection about inadequate particulars, raised for the first time in appeal, was rejected because it involved mixed questions of fact and law and had not been urged before the Adjudicating Authority. The admission of the section 95 applications was accordingly upheld.
Section 95(4)(a) of the Insolvency and Bankruptcy Code was treated as a completeness requirement for personal guarantor insolvency applications, not a rigid jurisdictional bar. Where liability was admitted through guarantee deeds, compromise terms and earlier judicial proceedings, the Appellate Tribunal held that the statutory purpose of disclosing debt was already satisfied and no further elaborate narration was necessary. A procedural objection about inadequate particulars, raised for the first time in appeal, was rejected because it involved mixed questions of fact and law and had not been urged before the Adjudicating Authority. The admission of the section 95 applications was accordingly upheld.
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