Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
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...
Pre-existing dispute over operational debt prevents Section 9 insolvency admission where contemporaneous correspondence and draft settlement material show a plausible, non-spurious contractual dispute. The Tribunal applied the Mobilox test and held that the Adjudicating Authority must only ask whether the defence raises a contention needing further investigation; it cannot decide merits or require prior civil, arbitral or debit-note proceedings as a condition for dispute. Disputed credits, work-completion certificates and settlement documents were treated as matters for fuller adjudication, and the order admitting CIRP was set aside.
Pre-existing dispute over operational debt prevents Section 9 insolvency admission where contemporaneous correspondence and draft settlement material show a plausible, non-spurious contractual dispute. The Tribunal applied the Mobilox test and held that the Adjudicating Authority must only ask whether the defence raises a contention needing further investigation; it cannot decide merits or require prior civil, arbitral or debit-note proceedings as a condition for dispute. Disputed credits, work-completion certificates and settlement documents were treated as matters for fuller adjudication, and the order admitting CIRP was set aside.
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