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...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Exclusion of appellant from the Committee of Creditors (CoC) - The Resolution Professional deemed Rare ARC (appellant) akin to a related party, thus ineligible for CoC participation - assignment of term loan in bad faith - The NCLAT found that the assignment from SEFL to Rare ARC was made under suspicious circumstances, with SEFL still holding a significant interest in the loan through security receipts. Moreover, allegations regarding the funding of the assignment transaction by SIFL and SEFL raised doubts about the bona fide nature of the assignment. Consequently, Rare ARC's appeal was dismissed, affirming its exclusion from the CoC.
Exclusion of appellant from the Committee of Creditors (CoC) - The Resolution Professional deemed Rare ARC (appellant) akin to a related party, thus ineligible for CoC participation - assignment of term loan in bad faith - The NCLAT found that the assignment from SEFL to Rare ARC was made under suspicious circumstances, with SEFL still holding a significant interest in the loan through security receipts. Moreover, allegations regarding the funding of the assignment transaction by SIFL and SEFL raised doubts about the bona fide nature of the assignment. Consequently, Rare ARC's appeal was dismissed, affirming its exclusion from the CoC.
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