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...
Regulation 31A authorises a regulatory fee on resolution plans as part of insolvency resolution process costs. The Insolvency and Bankruptcy Board's powers to levy fees and make regulations extend across the corporate insolvency resolution process and are not confined to service-provider registration or renewal. The residuary category of process costs may include the fee because the listed costs share no common genus limiting that power. The levy is a regulatory fee, not a tax: a broad nexus with regulatory services is sufficient and exact quid pro quo is unnecessary. It is neither arbitrary nor excessive merely because the regulator generates a surplus. The proviso applies prospectively to resolution plans pending adjudicatory approval and does not impose retrospective liability.
Regulation 31A authorises a regulatory fee on resolution plans as part of insolvency resolution process costs. The Insolvency and Bankruptcy Board's powers to levy fees and make regulations extend across the corporate insolvency resolution process and are not confined to service-provider registration or renewal. The residuary category of process costs may include the fee because the listed costs share no common genus limiting that power. The levy is a regulatory fee, not a tax: a broad nexus with regulatory services is sufficient and exact quid pro quo is unnecessary. It is neither arbitrary nor excessive merely because the regulator generates a surplus. The proviso applies prospectively to resolution plans pending adjudicatory approval and does not impose retrospective liability.
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