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...
Implementation of the Resolution Plan and change in management and control - Demand of customs duty - The appellant did not file any claim during the insolvency process, and as per provisions of the IBC, once a resolution plan is approved, all claims not part of the plan stand extinguished. The Court referred to relevant sections of the IBC and a Supreme Court ruling, affirming that once a resolution plan is approved, claims not included cease to exist. Consequently, the appeal was deemed abated, and the questions proposed were not answered.
Implementation of the Resolution Plan and change in management and control - Demand of customs duty - The appellant did not file any claim during the insolvency process, and as per provisions of the IBC, once a resolution plan is approved, all claims not part of the plan stand extinguished. The Court referred to relevant sections of the IBC and a Supreme Court ruling, affirming that once a resolution plan is approved, claims not included cease to exist. Consequently, the appeal was deemed abated, and the questions proposed were not answered.
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