Head Office cost allocation requires prescribed transfer-pricing methods; treaty ceilings bar surcharge and cess, while duplicate taxation is excluded...
Cost-to-cost reimbursement of seconded employees is not service consideration; transfer-pricing markup was deleted and amalgamation amortisation allow...
Crystallisation of liability supports prior-period expense deduction, while functionally distinct divisions require separate transfer-pricing benchmar...
Functional comparability under TNMM requires transaction-specific FAR analysis before benchmarking business-support services provided to associated en...
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Individual shareholders do not, merely by virtue of shareholding, qualify as aggrieved persons entitled to appeal approval of a corporate debtor's resolution plan. Allegations that post-approval modifications were fraudulent cannot expand standing unless supported by specific material. Homebuyers who have not independently challenged the resolution plan cannot contest it indirectly by supporting a shareholder's appeal. The shareholder's challenge to the approved resolution plan was therefore treated as not maintainable, and the related interlocutory applications were rejected.
Individual shareholders do not, merely by virtue of shareholding, qualify as aggrieved persons entitled to appeal approval of a corporate debtor's resolution plan. Allegations that post-approval modifications were fraudulent cannot expand standing unless supported by specific material. Homebuyers who have not independently challenged the resolution plan cannot contest it indirectly by supporting a shareholder's appeal. The shareholder's challenge to the approved resolution plan was therefore treated as not maintainable, and the related interlocutory applications were rejected.
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