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...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
Insolvency and BankruptcyJanuary 19, 2023Case LawsAT
Initiation of CIRP - Operational Debt or not - amount claimed by SDMC in connection with Toll Tax and ECC Agreement - Though the debt claimed by SDMC is an ‘operational debt’, there are clearly ‘pre-existing disputes’ raised by MEP Infrastructure regarding which litigations/dispute resolution mechanism have been pursued by both the parties in Hon’ble High Court and the internal forum of SDMC - Section 9 application has correctly been disallowed by the Adjudicating Authority. - AT
Initiation of CIRP - Operational Debt or not - amount claimed by SDMC in connection with Toll Tax and ECC Agreement - Though the debt claimed by SDMC is an ‘operational debt’, there are clearly ‘pre-existing disputes’ raised by MEP Infrastructure regarding which litigations/dispute resolution mechanism have been pursued by both the parties in Hon’ble High Court and the internal forum of SDMC - Section 9 application has correctly been disallowed by the Adjudicating Authority. - AT
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