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...
Maintainability of petition - Once it is admitted under IB Code initiating CIRP, which may end, either in approval of a resolution plan or an order for liquidation of the Corporate Debtor. Thus, under both situation, the management will never come again in the hands of the Suspended Management. - Even if the petition filed under Section 241-242 is kept in abeyance, then even it is not going to fulfil the objective of Section 241-242 of the Companies Act. Therefore, there is no reason for keeping the application filed under Section 241-242 be pending till the final outcome of the IB petition - Tri
Maintainability of petition - Once it is admitted under IB Code initiating CIRP, which may end, either in approval of a resolution plan or an order for liquidation of the Corporate Debtor. Thus, under both situation, the management will never come again in the hands of the Suspended Management. - Even if the petition filed under Section 241-242 is kept in abeyance, then even it is not going to fulfil the objective of Section 241-242 of the Companies Act. Therefore, there is no reason for keeping the application filed under Section 241-242 be pending till the final outcome of the IB petition - Tri
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