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 Section 10 application under IBC upheld as Appellant company filed it with unclean hands after evading Wilful Defaulter proceedings by Respondent Bank. Appellant selectively approached Bank for reprieve while avoiding proceedings, embroiling Bank in multiple litigations to stall recovery. Section 10 rights can't be misused to derive undue advantage over insolvency resolution objective. Adjudicating Authority rightly found Appellant's bonafides doubtful, filing motivated by reasons other than insolvency resolution. Appeal dismissed by NCLAT.
Rejection of Section 10 application under IBC upheld as Appellant company filed it with unclean hands after evading Wilful Defaulter proceedings by Respondent Bank. Appellant selectively approached Bank for reprieve while avoiding proceedings, embroiling Bank in multiple litigations to stall recovery. Section 10 rights can't be misused to derive undue advantage over insolvency resolution objective. Adjudicating Authority rightly found Appellant's bonafides doubtful, filing motivated by reasons other than insolvency resolution. Appeal dismissed by NCLAT.
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