Automated airline software subscriptions without human intervention fail technical-services characterisation and do not make available underlying tech...
Business support recruitment and training receipts qualify for presumptive business taxation, not professional taxation under technical consultancy ru...
Treaty exemption for foreign permanent-establishment management fees prevailed, while dividend expense disallowance remained limited to an accepted al...
Centralised assessment transfers: participation after requesting centralisation can bar technical jurisdictional challenges, while assessment disputes...
Binding precedent remains operative despite pending challenge, supporting deletion of interest disallowance when debt is converted into preference sha...
Individual shop owners intervening in representative oppression and mismanagement proceedings cannot independently challenge a final order where their grievances must be pursued in a representative capacity and the order establishes a class-wide mechanism. An intervenor who does not use the permitted representative route, while failing to disclose the order disposing of the intervention request, lacks a continuing individual right to appeal. After hearings conclude and written submissions are filed, additional material is not receivable as of right because other parties must have an opportunity to respond. Substantial relief also cannot be sought through a later individual intervention in proceedings instituted by others. The individual appeal was dismissed as non-maintainable, with exemplary costs.
Individual shop owners intervening in representative oppression and mismanagement proceedings cannot independently challenge a final order where their grievances must be pursued in a representative capacity and the order establishes a class-wide mechanism. An intervenor who does not use the permitted representative route, while failing to disclose the order disposing of the intervention request, lacks a continuing individual right to appeal. After hearings conclude and written submissions are filed, additional material is not receivable as of right because other parties must have an opportunity to respond. Substantial relief also cannot be sought through a later individual intervention in proceedings instituted by others. The individual appeal was dismissed as non-maintainable, with exemplary costs.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4927 
