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...
Suit for permanent injunction regarding outstanding dues and arrears of storage charges. Order VII Rule 11 CPC. Plaintiff specifically reserved rights in first suit regarding claim against warehousing charges, damages for illegal use and occupation, and applied for leave to file separate suit, which was granted. No relinquishment or omission to claim relief. Separate causes of action, second suit maintainable. Appellant facing recovery of over Rs. 8 crores, unnecessarily delaying suit pending since 2016. Impugned order does not suffer from infirmity. Appeal dismissed.
Suit for permanent injunction regarding outstanding dues and arrears of storage charges. Order VII Rule 11 CPC. Plaintiff specifically reserved rights in first suit regarding claim against warehousing charges, damages for illegal use and occupation, and applied for leave to file separate suit, which was granted. No relinquishment or omission to claim relief. Separate causes of action, second suit maintainable. Appellant facing recovery of over Rs. 8 crores, unnecessarily delaying suit pending since 2016. Impugned order does not suffer from infirmity. Appeal dismissed.
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