Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
In section 9 insolvency proceedings, the Appellate Tribunal held that the Adjudicating Authority may examine pleadings, agreements, audit material, acknowledgements and communications to determine debt and default, and that such scrutiny does not trespass into civil court jurisdiction. It rejected the argument that the summary nature of section 9 bars a detailed review of the record. On the facts, the agreements and email records contained clear admissions of liability, while the alleged dispute over damaged returned stock was treated as belated and unsupported by any independent suit, arbitration or other adjudicatory proceeding. The appeal was dismissed and admission of the application was upheld.
In section 9 insolvency proceedings, the Appellate Tribunal held that the Adjudicating Authority may examine pleadings, agreements, audit material, acknowledgements and communications to determine debt and default, and that such scrutiny does not trespass into civil court jurisdiction. It rejected the argument that the summary nature of section 9 bars a detailed review of the record. On the facts, the agreements and email records contained clear admissions of liability, while the alleged dispute over damaged returned stock was treated as belated and unsupported by any independent suit, arbitration or other adjudicatory proceeding. The appeal was dismissed and admission of the application was upheld.
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