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 application - initiation of CIRP - Whether the MOU dated 20 May 2016 is valid or not is a disputed question and needs further investigation. Such disputed question cannot be decided under the summary jurisdiction exercised by the Adjudicating Authority under the Insolvency and Bankruptcy Code, 2016. There is no debtor-creditor relationship between the Operational Creditor 'SPJV' and the Corporate Debtor 'GIPL'. Therefore, the Petition filed U/S Sec 9 is not maintainable. - AT
Maintainability of application - initiation of CIRP - Whether the MOU dated 20 May 2016 is valid or not is a disputed question and needs further investigation. Such disputed question cannot be decided under the summary jurisdiction exercised by the Adjudicating Authority under the Insolvency and Bankruptcy Code, 2016. There is no debtor-creditor relationship between the Operational Creditor 'SPJV' and the Corporate Debtor 'GIPL'. Therefore, the Petition filed U/S Sec 9 is not maintainable. - AT
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