Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
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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