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...
Remuneration payable to an IRP forms part of CIRP costs and is not excluded from judicial scrutiny merely because the CoC acts within commercial wisdom; fee fixation still requires examination of the factual basis, work performed and governing arrangement. However, on a reading of the first CoC meeting agenda, minutes and resolutions, the approved IRP remuneration was a consolidated amount, while monthly remuneration was linked to appointment as RP, which was rejected. The IRP had no vested right to continue, the replacement delay did not convert the fee into a monthly entitlement, and the later minimum-fee prescription was inapplicable. The fixed remuneration and expenses were upheld, and the claim for monthly remuneration for the entire tenure failed.
Remuneration payable to an IRP forms part of CIRP costs and is not excluded from judicial scrutiny merely because the CoC acts within commercial wisdom; fee fixation still requires examination of the factual basis, work performed and governing arrangement. However, on a reading of the first CoC meeting agenda, minutes and resolutions, the approved IRP remuneration was a consolidated amount, while monthly remuneration was linked to appointment as RP, which was rejected. The IRP had no vested right to continue, the replacement delay did not convert the fee into a monthly entitlement, and the later minimum-fee prescription was inapplicable. The fixed remuneration and expenses were upheld, and the claim for monthly remuneration for the entire tenure failed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4814 
Join Channel 
