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...
Advance pricing agreement methodology can guide benchmarking for non-covered years when functions, assets, risks and activities remain materially unch...
Tax-audit exemption for substantially State-funded educational universities prevents audit-failure penalties where income qualifies for statutory exem...
Functional, asset and risk analysis excludes diversified technology companies from captive software development comparables under cost-plus arrangemen...
Mobile-phone electronic evidence failed to establish customs undervaluation, while duty survived on non-authentic origin certificates without importer...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4902 
