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...
Limitation and jurisdiction objections to rejection of the plaint failed because the plaint, read as a whole, disputed any binding family settlement, pleaded later denial of the plaintiff's asserted share after the mother's death, and therefore raised facts requiring trial rather than an ex facie bar. The civil court's jurisdiction was also not ousted, as the suit was fundamentally an inheritance and partition dispute over company-linked assets, not merely oppression or mismanagement, and partial rejection of the plaint was impermissible. On a meaningful reading, the plaint disclosed a real cause of action.
Limitation and jurisdiction objections to rejection of the plaint failed because the plaint, read as a whole, disputed any binding family settlement, pleaded later denial of the plaintiff's asserted share after the mother's death, and therefore raised facts requiring trial rather than an ex facie bar. The civil court's jurisdiction was also not ousted, as the suit was fundamentally an inheritance and partition dispute over company-linked assets, not merely oppression or mismanagement, and partial rejection of the plaint was impermissible. On a meaningful reading, the plaint disclosed a real cause of action.
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