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 ...
Belated homebuyer claims reflected in the corporate debtor's records were not defeated by delay where the Resolution Professional showed no notice to the claimants, their registered agreement to sell and allotment details were available in the virtual data room, and the CIRP overlapped substantially with the Covid period; the claim was ordered to be admitted by addendum to the resolution plan. The Tribunal further held that purchasers with a registered agreement and recorded payment history were genuine homebuyers, not speculative investors, and therefore belonged in Category A of the plan. As the rival claimant sought refund with interest on assured-return reservation letters, the appellants were treated as having the superior claim and the impugned order was set aside.
Belated homebuyer claims reflected in the corporate debtor's records were not defeated by delay where the Resolution Professional showed no notice to the claimants, their registered agreement to sell and allotment details were available in the virtual data room, and the CIRP overlapped substantially with the Covid period; the claim was ordered to be admitted by addendum to the resolution plan. The Tribunal further held that purchasers with a registered agreement and recorded payment history were genuine homebuyers, not speculative investors, and therefore belonged in Category A of the plan. As the rival claimant sought refund with interest on assured-return reservation letters, the appellants were treated as having the superior claim and the impugned order was set aside.
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