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...
Regulation 21A deems a secured creditor to have relinquished security where it fails to intimate, within 30 days of liquidation commencement, its election to realise that security. A subsequent Form C claim does not displace this presumption. Where performance bank guarantees securing EPCG export obligations were neither invoked nor renewed, the underlying FDR amounts entered the liquidation estate following the customs creditor's deemed relinquishment. Directions requiring return of the original bonds and remittance of the FDR amounts to the liquidation account were affirmed, and the appeal was dismissed.
Regulation 21A deems a secured creditor to have relinquished security where it fails to intimate, within 30 days of liquidation commencement, its election to realise that security. A subsequent Form C claim does not displace this presumption. Where performance bank guarantees securing EPCG export obligations were neither invoked nor renewed, the underlying FDR amounts entered the liquidation estate following the customs creditor's deemed relinquishment. Directions requiring return of the original bonds and remittance of the FDR amounts to the liquidation account were affirmed, and the appeal was dismissed.
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