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 ...
Transfers of a corporate debtor's funds during the CIRP moratorium are prohibited where made without the Resolution Professional's knowledge, and transferred amounts may be directed to be remitted. Public announcement and publication of CIRP proceedings create deemed knowledge of the moratorium, preventing a recipient from relying on ignorance as a defence. A claim that transferred funds were held in trust requires proof of a trust relationship and a basis for identifying the funds as trust money; an unsupported assertion is insufficient. Proceedings for a moratorium breach may be pursued under Section 60(5) read with Section 14(1)(b). Reliance on Section 74 was unavailable where it was not previously pleaded and had been omitted by the 2026 amendment.
Transfers of a corporate debtor's funds during the CIRP moratorium are prohibited where made without the Resolution Professional's knowledge, and transferred amounts may be directed to be remitted. Public announcement and publication of CIRP proceedings create deemed knowledge of the moratorium, preventing a recipient from relying on ignorance as a defence. A claim that transferred funds were held in trust requires proof of a trust relationship and a basis for identifying the funds as trust money; an unsupported assertion is insufficient. Proceedings for a moratorium breach may be pursued under Section 60(5) read with Section 14(1)(b). Reliance on Section 74 was unavailable where it was not previously pleaded and had been omitted by the 2026 amendment.
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