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 HC upheld the Punjab and Maharashtra Co-Operative Bank Ltd. amalgamation scheme with Unity Small Finance Bank, finding no constitutional, statutory or procedural infirmity in the approval under the Banking Regulation Act. It held that judicial review of banking and economic policy is limited, and the RBI's decision was a public-interest measure justified by the bank's severe erosion of net worth and need to protect depositors. The Court also rejected challenges to depositor classification, staggered repayment and reduced interest, holding that retail and institutional depositors formed a valid distinction and that Section 45 permitted modification of depositor rights. Procedural objections on consultation, hearing and supersession of the board were also rejected.
The HC upheld the Punjab and Maharashtra Co-Operative Bank Ltd. amalgamation scheme with Unity Small Finance Bank, finding no constitutional, statutory or procedural infirmity in the approval under the Banking Regulation Act. It held that judicial review of banking and economic policy is limited, and the RBI's decision was a public-interest measure justified by the bank's severe erosion of net worth and need to protect depositors. The Court also rejected challenges to depositor classification, staggered repayment and reduced interest, holding that retail and institutional depositors formed a valid distinction and that Section 45 permitted modification of depositor rights. Procedural objections on consultation, hearing and supersession of the board were also rejected.
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