Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
Pre-existing disputes concerning the genuineness of purchase orders, supplies and underlying operational-debt transactions prevent corporate insolvency resolution proceedings from being used to determine contested claims. Information Utility records marked the debt as disputed, while the corporate debtor's legal notice and fraud-related complaints pre-dated the demand notice. As the dispute was neither spurious nor illusory and required detailed trial, a Section 9 application was not maintainable for adjudicating it. Rejection of the operational creditor's insolvency application was therefore sustained, and the appeal was dismissed.
Pre-existing disputes concerning the genuineness of purchase orders, supplies and underlying operational-debt transactions prevent corporate insolvency resolution proceedings from being used to determine contested claims. Information Utility records marked the debt as disputed, while the corporate debtor's legal notice and fraud-related complaints pre-dated the demand notice. As the dispute was neither spurious nor illusory and required detailed trial, a Section 9 application was not maintainable for adjudicating it. Rejection of the operational creditor's insolvency application was therefore sustained, and the appeal was dismissed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4894 
