Charitable sports promotion: sponsorship receipts alone did not defeat registration where funds supported tournaments and player development activitie...
Overdue associated-enterprise receivables: debt-free status defeated notional-interest adjustment, while employee stock-option costs qualified as busi...
Retrospective assessment-limitation amendments validate final orders while contemporaneous segment data governs transfer-pricing comparability and tol...
Transfer pricing adjustments must track international transactions, while unsupported AMP adjustments and unsuitable manufacturing comparables require...
Transfer-pricing adjustments must reflect functional comparability, working-capital effects, and avoid duplicating interest on associated-enterprise r...
Section 32A protection extends the clean slate principle to a corporate debtor sold as a going concern during liquidation, subject to fulfilment of statutory conditions. Unclaimed past liabilities, pending or future proceedings, and pre-existing non-compliances cannot continue against the purchaser after completion of the sale where the statutory protection applies. This consequence arises by operation of law rather than as a discretionary waiver or concession. Purchasers seeking waivers or concessions concerning past liabilities must pursue those requests before the relevant statutory authorities.
Section 32A protection extends the clean slate principle to a corporate debtor sold as a going concern during liquidation, subject to fulfilment of statutory conditions. Unclaimed past liabilities, pending or future proceedings, and pre-existing non-compliances cannot continue against the purchaser after completion of the sale where the statutory protection applies. This consequence arises by operation of law rather than as a discretionary waiver or concession. Purchasers seeking waivers or concessions concerning past liabilities must pursue those requests before the relevant statutory authorities.
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