Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
Clean slate principle bars revival of pre-CIRP electricity dues and the connected late payment surcharge after approval of a resolution plan. Where the surcharge had already arisen on unpaid electricity charges before CIRP, extinguishment of the principal pre-resolution claim also prevents indirect recovery of the related surcharge as a condition for restoring supply. Reliance on post-disconnection billing or section 56(2) concepts was misplaced because the liability had already been billed and formed part of the pre-CIRP dues. A demand for pre-CIRP surcharge as a precondition to a fresh electricity connection was therefore treated as arbitrary and without authority of law.
Clean slate principle bars revival of pre-CIRP electricity dues and the connected late payment surcharge after approval of a resolution plan. Where the surcharge had already arisen on unpaid electricity charges before CIRP, extinguishment of the principal pre-resolution claim also prevents indirect recovery of the related surcharge as a condition for restoring supply. Reliance on post-disconnection billing or section 56(2) concepts was misplaced because the liability had already been billed and formed part of the pre-CIRP dues. A demand for pre-CIRP surcharge as a precondition to a fresh electricity connection was therefore treated as arbitrary and without authority of law.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4803
Join Channel
TaxTMI 
