Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Completed liquidation and sale of a corporate debtor as a going concern can make income-tax appeals on pre-IBC additions infructuous where the liquidation has closed and subsisting NCLT directions require pre-transfer liabilities to be dealt with only within the IBC framework. Because assessments, notices and proceedings for the pre-transfer period were barred against the transferred entity and its successors, the Tribunal treated any merits adjudication as academic and disposed of the appeals without examining the additions. The note also clarifies that the outcome was confined to the corporate debtor and did not decide any independent action against former management or other persons.
Completed liquidation and sale of a corporate debtor as a going concern can make income-tax appeals on pre-IBC additions infructuous where the liquidation has closed and subsisting NCLT directions require pre-transfer liabilities to be dealt with only within the IBC framework. Because assessments, notices and proceedings for the pre-transfer period were barred against the transferred entity and its successors, the Tribunal treated any merits adjudication as academic and disposed of the appeals without examining the additions. The note also clarifies that the outcome was confined to the corporate debtor and did not decide any independent action against former management or other persons.
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