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...
Validity of Resolution Plan - closure of CD - Resolution Plan is against the object of the Code and the application u/s 10 was filed with intent of closure of the Corporate Debtor for a purpose other than for the resolution of insolvency, or liquidation is against the scope and intent of the ‘I&B Code’ is in violation of Section 30(2)(e) - part of the approved Plan relates to closure of the CD is is set aside and rest part is approved
Validity of Resolution Plan - closure of CD - Resolution Plan is against the object of the Code and the application u/s 10 was filed with intent of closure of the Corporate Debtor for a purpose other than for the resolution of insolvency, or liquidation is against the scope and intent of the ‘I&B Code’ is in violation of Section 30(2)(e) - part of the approved Plan relates to closure of the CD is is set aside and rest part is approved
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