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 BankruptcyDecember 8, 2022Case LawsAT
Initiation of CIRP - Financial creditors - The use of the word ‘if any’ clearly makes that it is not essential for all financial debt to be with interest. However, the essential condition which is required to be fulfilled for a debt to be a financial debt is “disbursement for time value of money” which has to be fulfilled for all transactions referred to in clauses (a) to (f) in sub-section (8) of Section 5 of the Code. - AT
Initiation of CIRP - Financial creditors - The use of the word ‘if any’ clearly makes that it is not essential for all financial debt to be with interest. However, the essential condition which is required to be fulfilled for a debt to be a financial debt is “disbursement for time value of money” which has to be fulfilled for all transactions referred to in clauses (a) to (f) in sub-section (8) of Section 5 of the Code. - AT
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