Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
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...
Deed of pledge of shares - voting right - The express terms of the Deed of Pledge will prevail - In the present case the use of the pledged goods will include exercise of voting rights since the pledged goods are shares. Thus, the Pledge Deeds by including in its terms the exercise of voting rights of the Pledgee will neither be contrary to law nor lead to conversion nor would amount to mortgage of movables. - HC
Deed of pledge of shares - voting right - The express terms of the Deed of Pledge will prevail - In the present case the use of the pledged goods will include exercise of voting rights since the pledged goods are shares. Thus, the Pledge Deeds by including in its terms the exercise of voting rights of the Pledgee will neither be contrary to law nor lead to conversion nor would amount to mortgage of movables. - HC
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