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...
An operational creditor sought to assail approval of a CIRP resolution plan through collateral proceedings, contending prejudice in payments vis-Ã -vis liquidation value. The record showed the creditor had prior knowledge of the plan and CoC deliberations, including receipt of minutes before adjudicating authority approval, and had even acted on that knowledge by seeking to submit its own plan. Having failed to institute a proper statutory challenge to the plan approval within the prescribed framework, the creditor could not maintain an indirect, parallel challenge to reopen the plan. The appeals were dismissed and the plan approval was left undisturbed. - SC
An operational creditor sought to assail approval of a CIRP resolution plan through collateral proceedings, contending prejudice in payments vis-Ã -vis liquidation value. The record showed the creditor had prior knowledge of the plan and CoC deliberations, including receipt of minutes before adjudicating authority approval, and had even acted on that knowledge by seeking to submit its own plan. Having failed to institute a proper statutory challenge to the plan approval within the prescribed framework, the creditor could not maintain an indirect, parallel challenge to reopen the plan. The appeals were dismissed and the plan approval was left undisturbed. - SC
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