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...
Demand of KGST when the resolution plan was approved - Jurisdiction and applicability of the Insolvency and Bankruptcy Code (IBC) over statutory dues. The court referenced the Supreme Court's ruling in Ghanasyam Mishra that all claims not part of the resolution plan stand extinguished upon its approval. However, the court also acknowledged the Rainbow Papers judgment, which emphasized that a resolution plan must comply with statutory provisions and cannot ignore statutory dues. The court found that the assessment order did not examine whether the resolution plan met the requirements of Section 30(2) of the IBC.
Demand of KGST when the resolution plan was approved - Jurisdiction and applicability of the Insolvency and Bankruptcy Code (IBC) over statutory dues. The court referenced the Supreme Court's ruling in Ghanasyam Mishra that all claims not part of the resolution plan stand extinguished upon its approval. However, the court also acknowledged the Rainbow Papers judgment, which emphasized that a resolution plan must comply with statutory provisions and cannot ignore statutory dues. The court found that the assessment order did not examine whether the resolution plan met the requirements of Section 30(2) of the IBC.
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