Marketing support and subcontracted client contracts: no agency permanent establishment under Article 5 DTAA; arm's-length pricing bars profit attribu...
Transfer pricing comparables selection and working capital adjustment u/r 10B(1)(e)(iii), remanded for recomputation with rejected comparables include...
Regulation 38 of the CIRP Regulations, 2016 is amended by inserting sub-regulation (3A) requiring every resolution plan to include (i) a beneficial-ownership statement, in the format to be specified by IBBI through circular, disclosing all natural persons who ultimately own or control the resolution applicant, along with the applicant's shareholding structure and the jurisdiction of each intermediate entity, and (ii) an affidavit, in the format specified by the Board, stating whether the resolution applicant is eligible or not eligible for the benefit of section 32A. These additions make such ownership disclosures and the section 32A eligibility declaration mandatory components of any resolution plan, effective from publication in the Official Gazette.
Regulation 38 of the CIRP Regulations, 2016 is amended by inserting sub-regulation (3A) requiring every resolution plan to include (i) a beneficial-ownership statement, in the format to be specified by IBBI through circular, disclosing all natural persons who ultimately own or control the resolution applicant, along with the applicant's shareholding structure and the jurisdiction of each intermediate entity, and (ii) an affidavit, in the format specified by the Board, stating whether the resolution applicant is eligible or not eligible for the benefit of section 32A. These additions make such ownership disclosures and the section 32A eligibility declaration mandatory components of any resolution plan, effective from publication in the Official Gazette.
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