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 ...
Regulation 31A authorises a regulatory fee on resolution plans as part of insolvency resolution process costs. The Insolvency and Bankruptcy Board's powers to levy fees and make regulations extend across the corporate insolvency resolution process and are not confined to service-provider registration or renewal. The residuary category of process costs may include the fee because the listed costs share no common genus limiting that power. The levy is a regulatory fee, not a tax: a broad nexus with regulatory services is sufficient and exact quid pro quo is unnecessary. It is neither arbitrary nor excessive merely because the regulator generates a surplus. The proviso applies prospectively to resolution plans pending adjudicatory approval and does not impose retrospective liability.
Regulation 31A authorises a regulatory fee on resolution plans as part of insolvency resolution process costs. The Insolvency and Bankruptcy Board's powers to levy fees and make regulations extend across the corporate insolvency resolution process and are not confined to service-provider registration or renewal. The residuary category of process costs may include the fee because the listed costs share no common genus limiting that power. The levy is a regulatory fee, not a tax: a broad nexus with regulatory services is sufficient and exact quid pro quo is unnecessary. It is neither arbitrary nor excessive merely because the regulator generates a surplus. The proviso applies prospectively to resolution plans pending adjudicatory approval and does not impose retrospective liability.
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