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...
The NCLAT held that Compulsory Convertible Debentures (CCDs) issued by the Corporate Debtor constituted a 'financial debt' u/s 5(8) as the transaction involved time value of money. The debenture subscription agreement contemplated redemption and conversion was at the option of the investor. Considering the clauses, the CCDs reflected time value of money, making it a financial debt. The NCLAT dismissed the appeal, upholding the adjudicating authority's order allowing the respondent's application.
The NCLAT held that Compulsory Convertible Debentures (CCDs) issued by the Corporate Debtor constituted a 'financial debt' u/s 5(8) as the transaction involved time value of money. The debenture subscription agreement contemplated redemption and conversion was at the option of the investor. Considering the clauses, the CCDs reflected time value of money, making it a financial debt. The NCLAT dismissed the appeal, upholding the adjudicating authority's order allowing the respondent's application.
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