Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Dismissal of Section 9 for initiation of CIRP - Period of limitation - The Adjudicating Authority held that the debt was time-barred as per the Limitation Act. It noted that 26 out of 27 invoices submitted by the Operational Creditor were more than three years old from the date of filing the Section 9 application, and no subsequent acknowledgment of liability was provided to extend the limitation period. - The Tribunal (NCLAT) dismissed the appeal, affirming the Adjudicating Authority's order.
Dismissal of Section 9 for initiation of CIRP - Period of limitation - The Adjudicating Authority held that the debt was time-barred as per the Limitation Act. It noted that 26 out of 27 invoices submitted by the Operational Creditor were more than three years old from the date of filing the Section 9 application, and no subsequent acknowledgment of liability was provided to extend the limitation period. - The Tribunal (NCLAT) dismissed the appeal, affirming the Adjudicating Authority's order.
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