Marketing support and subcontracted client contracts: no agency permanent establishment under Article 5 DTAA; arm's-length pricing bars profit attribu...
Approved resolution plans under the IBC extinguish pre-CIRP tax demands, and belated claims cannot be enforced against the corporate debtor once the plan is sanctioned on a clean-slate basis. Applying that principle, the High Court directed the Revenue to give effect to the NCLT-approved plan, delete all pre-resolution-plan demands from the Income Tax Portal, recompute the petitioner's liability or refund, and issue any consequential refund within the stipulated time.
Approved resolution plans under the IBC extinguish pre-CIRP tax demands, and belated claims cannot be enforced against the corporate debtor once the plan is sanctioned on a clean-slate basis. Applying that principle, the High Court directed the Revenue to give effect to the NCLT-approved plan, delete all pre-resolution-plan demands from the Income Tax Portal, recompute the petitioner's liability or refund, and issue any consequential refund within the stipulated time.
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