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...
Operational debt may arise from an advance paid for goods where a consortium agreement assigns supply obligations to the corporate debtor and other evidence establishes the commercial nexus; an invoice is not indispensable. Receipt of the advance, cheques issued by the corporate debtor, and a later withdrawn invoice supported characterisation as payment for supplies rather than an unsupported security deposit. A pre-existing dispute must exist before the demand notice; post-notice objections and account-reconciliation assertions do not suffice. The insolvency application was revived for admission, subject to a time-bound opportunity for the corporate debtor to prove payment.
Operational debt may arise from an advance paid for goods where a consortium agreement assigns supply obligations to the corporate debtor and other evidence establishes the commercial nexus; an invoice is not indispensable. Receipt of the advance, cheques issued by the corporate debtor, and a later withdrawn invoice supported characterisation as payment for supplies rather than an unsupported security deposit. A pre-existing dispute must exist before the demand notice; post-notice objections and account-reconciliation assertions do not suffice. The insolvency application was revived for admission, subject to a time-bound opportunity for the corporate debtor to prove payment.
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