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 ...
Rejection of claim by Resolution Professional - Petitioners sought return of stock of their owned rice from the Corporate Debtor - to accept the claims of the Appellants at the stage of Resolution and now Liquidation proceedings, the claims have to be real, based on solid documentary evidence and in accordance with law. These cannot be allowed on the basis of indirect or circumstantial or secondary evidence/ documents. - AT
Rejection of claim by Resolution Professional - Petitioners sought return of stock of their owned rice from the Corporate Debtor - to accept the claims of the Appellants at the stage of Resolution and now Liquidation proceedings, the claims have to be real, based on solid documentary evidence and in accordance with law. These cannot be allowed on the basis of indirect or circumstantial or secondary evidence/ documents. - AT
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