Related-party creditor exclusion bars CoC participation where lender rights show policy-making involvement, and post-CIRP assignment cannot cure ineli...
Rectification of apparent typographical errors may proceed without hearing when tax liability, input tax credit, and ruling substance remain unchanged...
Corporate guarantees furnished to wholly owned foreign subsidiaries are international transactions under the Explanation to Section 92B and require arm's-length benchmarking; a 0.50% guarantee commission applies rather than 1%. Sales commission paid to a United States associated enterprise for marketing and support services did not constitute fees for included services under Article 12(4)(b) of the India-US tax treaty and was not taxable in India; therefore, no withholding obligation or consequential disallowance arose. The SEZ-unit deduction claim requires reconsideration using Form 56F, a bifurcated profit and loss statement, and the computation of eligible profits, without a merits determination of eligibility or quantum.
Corporate guarantees furnished to wholly owned foreign subsidiaries are international transactions under the Explanation to Section 92B and require arm's-length benchmarking; a 0.50% guarantee commission applies rather than 1%. Sales commission paid to a United States associated enterprise for marketing and support services did not constitute fees for included services under Article 12(4)(b) of the India-US tax treaty and was not taxable in India; therefore, no withholding obligation or consequential disallowance arose. The SEZ-unit deduction claim requires reconsideration using Form 56F, a bifurcated profit and loss statement, and the computation of eligible profits, without a merits determination of eligibility or quantum.
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