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...
NCLAT dismissed an appeal u/s approval of Resolution Plan by dissenting Financial Creditors objecting to Homebuyers receiving flats without price escalation. Held that Homebuyers, with fixed consideration, can receive units as agreed. No violation of Section 30(2) found, as Homebuyers were treated differently but not discriminated against. Dissenting Financial Creditors entitled to payment u/s 30(2)(b)(ii). They cannot claim payment based on security interest. Appeal dismissed.
NCLAT dismissed an appeal u/s approval of Resolution Plan by dissenting Financial Creditors objecting to Homebuyers receiving flats without price escalation. Held that Homebuyers, with fixed consideration, can receive units as agreed. No violation of Section 30(2) found, as Homebuyers were treated differently but not discriminated against. Dissenting Financial Creditors entitled to payment u/s 30(2)(b)(ii). They cannot claim payment based on security interest. Appeal dismissed.
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