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...
CIRP - Dismissal of application filed u/s 7 of the Insolvency and Bankruptcy Code, 2016 - Distinction between financial debt owed by the Corporate Debtor and the lack of privity of contract between the parties. - Despite claims by the appellants that the money was not repaid, the Tribunal found that there was no legal obligation on the part of the Corporate Debtor to repay the loan disbursed to the vendor. The Tribunal highlighted the lack of evidence supporting the money given as a loan, leading to the dismissal of the application under Section 7 of the IBC.
CIRP - Dismissal of application filed u/s 7 of the Insolvency and Bankruptcy Code, 2016 - Distinction between financial debt owed by the Corporate Debtor and the lack of privity of contract between the parties. - Despite claims by the appellants that the money was not repaid, the Tribunal found that there was no legal obligation on the part of the Corporate Debtor to repay the loan disbursed to the vendor. The Tribunal highlighted the lack of evidence supporting the money given as a loan, leading to the dismissal of the application under Section 7 of the IBC.
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