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...
Insolvency and BankruptcyFebruary 1, 2022Case LawsAT
Seeking Liquidation of Corporate Debtor - Eligibility under the amended MSME Act 2006, Notified on 26.06.2020 - After going through the contents of the Notification, dated 26.06.2020, under the MSME Act, 2006, this Tribunal arrives at a definite conclusion that the said notification is only ‘Prospective in nature’ and not a ‘Retrospective’ one because the said notification does not in express terms speak about the applicability of retrospective operation. The relevant words are conspicuously absent besides there being no implicit reference to be drawn for such a construction. - AT
Seeking Liquidation of Corporate Debtor - Eligibility under the amended MSME Act 2006, Notified on 26.06.2020 - After going through the contents of the Notification, dated 26.06.2020, under the MSME Act, 2006, this Tribunal arrives at a definite conclusion that the said notification is only ‘Prospective in nature’ and not a ‘Retrospective’ one because the said notification does not in express terms speak about the applicability of retrospective operation. The relevant words are conspicuously absent besides there being no implicit reference to be drawn for such a construction. - AT
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