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...
Post-approval tariff revision did not create an independent right to refund or set-off for pre-CIRP electricity dues where the approved resolution plan had already settled and frozen pre-CIRP liabilities inter se the parties. The revised bills were treated only as an internal accounting adjustment reflecting the reduced extent of the respondent's pre-CIRP claim and bad debt, not as an enforceable fresh demand against the appellant beyond the plan amount. Since no additional pre-CIRP liability was fastened, the requests for adjustment and refund were not maintainable, and the reconnection prayer did not survive separately because a direction had already been issued.
Post-approval tariff revision did not create an independent right to refund or set-off for pre-CIRP electricity dues where the approved resolution plan had already settled and frozen pre-CIRP liabilities inter se the parties. The revised bills were treated only as an internal accounting adjustment reflecting the reduced extent of the respondent's pre-CIRP claim and bad debt, not as an enforceable fresh demand against the appellant beyond the plan amount. Since no additional pre-CIRP liability was fastened, the requests for adjustment and refund were not maintainable, and the reconnection prayer did not survive separately because a direction had already been issued.
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