Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
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The NCLAT dismissed the appeals, upholding the adjudicating authority's rejection under s.114(1) of the I&B Code of the appellants' repayment plan(s) for personal guarantors. The Tribunal found no evidence of a group insolvency process, recorded an apparent failure by the appellants to furnish the modified repayment plan within prescribed timeframes after meetings on 29.11.2022 and 01.12.2022, and held that denial of revision under s.115 did not disclose any manifest error warranting interference. Subsequent initiation of proceedings under s.123 and the declaration of corporate guarantors' bankruptcy on 18.04.2024 further rendered the limited challenge to the repayment-plan rejection devoid of practical relief.
The NCLAT dismissed the appeals, upholding the adjudicating authority's rejection under s.114(1) of the I&B Code of the appellants' repayment plan(s) for personal guarantors. The Tribunal found no evidence of a group insolvency process, recorded an apparent failure by the appellants to furnish the modified repayment plan within prescribed timeframes after meetings on 29.11.2022 and 01.12.2022, and held that denial of revision under s.115 did not disclose any manifest error warranting interference. Subsequent initiation of proceedings under s.123 and the declaration of corporate guarantors' bankruptcy on 18.04.2024 further rendered the limited challenge to the repayment-plan rejection devoid of practical relief.
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