Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
Scientific Research approval for Sikshya O Anusandhan under section 35(1)(ii) granted subject to reporting, certification, and compliance requirements...
Direct disbursement to the corporate debtor is not mandated for classification as financial debt; funds advanced on behalf of or for the benefit of the corporate debtor may satisfy the disbursement element depending on the contractual and factual matrix. A covenant to pay in supplemental mortgage deeds, read with the debenture trust deed and related documents, operates as an enforceable contract of guarantee converting the claim into a secured financial debt. Substance of the transaction (express payment undertaking and joint-and-several liability) governs classification, and the matter is remitted for fresh adjudication consistent with these principles.
Direct disbursement to the corporate debtor is not mandated for classification as financial debt; funds advanced on behalf of or for the benefit of the corporate debtor may satisfy the disbursement element depending on the contractual and factual matrix. A covenant to pay in supplemental mortgage deeds, read with the debenture trust deed and related documents, operates as an enforceable contract of guarantee converting the claim into a secured financial debt. Substance of the transaction (express payment undertaking and joint-and-several liability) governs classification, and the matter is remitted for fresh adjudication consistent with these principles.
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