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...
A liquidation claim filed after a 787-day delay was rejected because Regulation 12(2)(b) requires claims to be lodged or updated within the prescribed time, and insolvency law treats timeliness as central to the liquidation process. Even if the timeline were treated as directory, an inordinate delay still needed a satisfactory explanation, which was absent here. The pendency or abatement of customs proceedings did not bar filing the claim before the liquidator, and a government department was not entitled to any special indulgence in condonation of delay. Entertaining the belated claim at an advanced stage would disrupt the liquidation process, so the rejection was upheld.
A liquidation claim filed after a 787-day delay was rejected because Regulation 12(2)(b) requires claims to be lodged or updated within the prescribed time, and insolvency law treats timeliness as central to the liquidation process. Even if the timeline were treated as directory, an inordinate delay still needed a satisfactory explanation, which was absent here. The pendency or abatement of customs proceedings did not bar filing the claim before the liquidator, and a government department was not entitled to any special indulgence in condonation of delay. Entertaining the belated claim at an advanced stage would disrupt the liquidation process, so the rejection was upheld.
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