Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
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...
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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