Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Interference with an approved resolution plan under the Insolvency and Bankruptcy Code is confined to patent illegality, material irregularity, violation of mandatory law, or perversity, and a completed insolvency process cannot be reopened for mere dissatisfaction with claim treatment. The appellant's claim remained disputed and contingent throughout verification because of reciprocal contractual claims and counter-claims, so there was no admitted operational debt and no basis for invoking notice rights under Section 24(3)(c). Allegations of fraud, suppression, and procedural impropriety were unsupported, and the appellant showed no material prejudice affecting the resolution outcome. The appeal was dismissed, and the approved and implemented plan was left undisturbed.
Interference with an approved resolution plan under the Insolvency and Bankruptcy Code is confined to patent illegality, material irregularity, violation of mandatory law, or perversity, and a completed insolvency process cannot be reopened for mere dissatisfaction with claim treatment. The appellant's claim remained disputed and contingent throughout verification because of reciprocal contractual claims and counter-claims, so there was no admitted operational debt and no basis for invoking notice rights under Section 24(3)(c). Allegations of fraud, suppression, and procedural impropriety were unsupported, and the appellant showed no material prejudice affecting the resolution outcome. The appeal was dismissed, and the approved and implemented plan was left undisturbed.
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