Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Insolvency and BankruptcyNovember 26, 2022Case LawsAT
Initiation of CIRP - time limitation - there is no support to the submission from the Section 10A that the prohibition from initiation of CIRP was limited for six months or one year and after expiry of that period an application can be filed for period covered by Section 10A also. The use of the expression in the proviso that no application shall ever be filed is clearly clarificatory of legislative intendment as contained in Section 10A. - AT
Initiation of CIRP - time limitation - there is no support to the submission from the Section 10A that the prohibition from initiation of CIRP was limited for six months or one year and after expiry of that period an application can be filed for period covered by Section 10A also. The use of the expression in the proviso that no application shall ever be filed is clearly clarificatory of legislative intendment as contained in Section 10A. - AT
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