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...
Section 96(4) of the Insolvency and Bankruptcy Code applies retroactively to pending insolvency applications involving personal guarantors to corporate debtors. The exclusion removes the pre-admission interim moratorium that could otherwise delay recovery proceedings; it affects pending transactions rather than completed transactions. The phrase "is filed" includes applications filed before the amendment's commencement but still pending thereafter. Consequently, the personal guarantor could not rely on an interim moratorium to bar the suit, and the request to reject the plaint on that basis was dismissed.
Section 96(4) of the Insolvency and Bankruptcy Code applies retroactively to pending insolvency applications involving personal guarantors to corporate debtors. The exclusion removes the pre-admission interim moratorium that could otherwise delay recovery proceedings; it affects pending transactions rather than completed transactions. The phrase "is filed" includes applications filed before the amendment's commencement but still pending thereafter. Consequently, the personal guarantor could not rely on an interim moratorium to bar the suit, and the request to reject the plaint on that basis was dismissed.
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