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...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Distribution under a resolution plan among secured financial creditors may be determined through the Committee of Creditors' commercial wisdom, subject to the statutory minimum payable to dissenting financial creditors. A dissenting secured creditor cannot demand a larger share solely by relying on the value of its individual security interest. Pro rata allocation based on claims admitted by the resolution professional during CIRP, including stage-wise receipt of plan funds, is consistent with this principle. The approved distribution according to admitted claim ratios, rather than individual security interests, was sustained and the appeals were dismissed.
Distribution under a resolution plan among secured financial creditors may be determined through the Committee of Creditors' commercial wisdom, subject to the statutory minimum payable to dissenting financial creditors. A dissenting secured creditor cannot demand a larger share solely by relying on the value of its individual security interest. Pro rata allocation based on claims admitted by the resolution professional during CIRP, including stage-wise receipt of plan funds, is consistent with this principle. The approved distribution according to admitted claim ratios, rather than individual security interests, was sustained and the appeals were dismissed.
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