Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law...
Res judicata barred the challenge because it repeated issues already decided against the successful resolution applicant, and the liquidation direction merely carried forward earlier final orders aimed at closure under the insolvency framework. The tribunal held that a post-reservation application for a one-time payment proposal did not create any right to rehearing, and the unilateral restructuring plea was a belated attempt to obstruct liquidation. It also held that regulatory approvals were the applicant's own responsibility under the approved plan; mere pendency of approval requests and repeated non-payment could not justify indefinite delay. Prolonged non-implementation, value erosion and lack of credible performance therefore justified liquidation, and the appeal was dismissed with costs.
Res judicata barred the challenge because it repeated issues already decided against the successful resolution applicant, and the liquidation direction merely carried forward earlier final orders aimed at closure under the insolvency framework. The tribunal held that a post-reservation application for a one-time payment proposal did not create any right to rehearing, and the unilateral restructuring plea was a belated attempt to obstruct liquidation. It also held that regulatory approvals were the applicant's own responsibility under the approved plan; mere pendency of approval requests and repeated non-payment could not justify indefinite delay. Prolonged non-implementation, value erosion and lack of credible performance therefore justified liquidation, and the appeal was dismissed with costs.
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