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...
The insolvency admission was upheld because the corporate debtor could not reopen the validity of bank guarantee invocation after the DRT had already found that the guarantees were invoked before expiry and that finding had attained finality. The tribunal also treated the later one time settlement as a formal acknowledgment of the outstanding debt, and the debtor's failure to comply with that settlement constituted default. In view of the admitted sanction of the credit facility, execution of the corporate guarantee and mortgage, and remittance by the bank on invocation, the challenge to admission was untenable and the insolvency application remained valid.
The insolvency admission was upheld because the corporate debtor could not reopen the validity of bank guarantee invocation after the DRT had already found that the guarantees were invoked before expiry and that finding had attained finality. The tribunal also treated the later one time settlement as a formal acknowledgment of the outstanding debt, and the debtor's failure to comply with that settlement constituted default. In view of the admitted sanction of the credit facility, execution of the corporate guarantee and mortgage, and remittance by the bank on invocation, the challenge to admission was untenable and the insolvency application remained valid.
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