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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...
The AT affirms that alleged collusion between bank officials and the directors of the company is not foreclosed and must be adjudicated by the Special Judge, PMLA, in the trial court. The AT holds that where two statutes conflict, the later enactment prevails absent a saving clause. The liquidator of the company is granted leave to move the Special Judge, PMLA, under section 8(7) of the PMLA for permission to auction the specified property to satisfy the consortium of banks and other creditors; the liquidator must undertake to deposit any surplus realisation in an FDR with the Respondent and the Special Judge will adjudicate its disposal after conclusion of the PMLA trial. Appeal dismissed.
The AT affirms that alleged collusion between bank officials and the directors of the company is not foreclosed and must be adjudicated by the Special Judge, PMLA, in the trial court. The AT holds that where two statutes conflict, the later enactment prevails absent a saving clause. The liquidator of the company is granted leave to move the Special Judge, PMLA, under section 8(7) of the PMLA for permission to auction the specified property to satisfy the consortium of banks and other creditors; the liquidator must undertake to deposit any surplus realisation in an FDR with the Respondent and the Special Judge will adjudicate its disposal after conclusion of the PMLA trial. Appeal dismissed.
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