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 ...
Remuneration payable to an IRP forms part of CIRP costs and is not excluded from judicial scrutiny merely because the CoC acts within commercial wisdom; fee fixation still requires examination of the factual basis, work performed and governing arrangement. However, on a reading of the first CoC meeting agenda, minutes and resolutions, the approved IRP remuneration was a consolidated amount, while monthly remuneration was linked to appointment as RP, which was rejected. The IRP had no vested right to continue, the replacement delay did not convert the fee into a monthly entitlement, and the later minimum-fee prescription was inapplicable. The fixed remuneration and expenses were upheld, and the claim for monthly remuneration for the entire tenure failed.
Remuneration payable to an IRP forms part of CIRP costs and is not excluded from judicial scrutiny merely because the CoC acts within commercial wisdom; fee fixation still requires examination of the factual basis, work performed and governing arrangement. However, on a reading of the first CoC meeting agenda, minutes and resolutions, the approved IRP remuneration was a consolidated amount, while monthly remuneration was linked to appointment as RP, which was rejected. The IRP had no vested right to continue, the replacement delay did not convert the fee into a monthly entitlement, and the later minimum-fee prescription was inapplicable. The fixed remuneration and expenses were upheld, and the claim for monthly remuneration for the entire tenure failed.
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