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...
Revenue entitlement to recover dues for the period which precedes the date of approval of the RP by the NCLT under IBC - Extinguishment of liability as per the approved resolution plan - A successful applicant is, in law, provided with a “clean slate”; therefore, dues for the period prior to the date when the RP was approved cannot be recovered. The courts have recognized this principle in more than one case. - HC
Revenue entitlement to recover dues for the period which precedes the date of approval of the RP by the NCLT under IBC - Extinguishment of liability as per the approved resolution plan - A successful applicant is, in law, provided with a “clean slate”; therefore, dues for the period prior to the date when the RP was approved cannot be recovered. The courts have recognized this principle in more than one case. - HC
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