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...
Clean slate principle bars revival of pre-CIRP electricity dues and the connected late payment surcharge after approval of a resolution plan. Where the surcharge had already arisen on unpaid electricity charges before CIRP, extinguishment of the principal pre-resolution claim also prevents indirect recovery of the related surcharge as a condition for restoring supply. Reliance on post-disconnection billing or section 56(2) concepts was misplaced because the liability had already been billed and formed part of the pre-CIRP dues. A demand for pre-CIRP surcharge as a precondition to a fresh electricity connection was therefore treated as arbitrary and without authority of law.
Clean slate principle bars revival of pre-CIRP electricity dues and the connected late payment surcharge after approval of a resolution plan. Where the surcharge had already arisen on unpaid electricity charges before CIRP, extinguishment of the principal pre-resolution claim also prevents indirect recovery of the related surcharge as a condition for restoring supply. Reliance on post-disconnection billing or section 56(2) concepts was misplaced because the liability had already been billed and formed part of the pre-CIRP dues. A demand for pre-CIRP surcharge as a precondition to a fresh electricity connection was therefore treated as arbitrary and without authority of law.
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