Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
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Corporate guarantee and cost-overrun undertakings were interpreted as limited obligations to infuse equity, meet shortfalls, or cover specified contingencies; they did not create a liability to repay the principal borrower's loan, so a Section 7 petition against the corporate debtor was not maintainable on that basis. The tribunal also held that default of the principal borrower could not be treated as the guarantor's default; default arose only after invocation of the guarantee and non-payment thereafter, which on the bank's own case fell within the Section 10A suspension period. Non-consideration of the later guarantee deed and inconsistent treatment of the same transaction further indicated non-application of mind, making the admission order unsustainable.
Corporate guarantee and cost-overrun undertakings were interpreted as limited obligations to infuse equity, meet shortfalls, or cover specified contingencies; they did not create a liability to repay the principal borrower's loan, so a Section 7 petition against the corporate debtor was not maintainable on that basis. The tribunal also held that default of the principal borrower could not be treated as the guarantor's default; default arose only after invocation of the guarantee and non-payment thereafter, which on the bank's own case fell within the Section 10A suspension period. Non-consideration of the later guarantee deed and inconsistent treatment of the same transaction further indicated non-application of mind, making the admission order unsustainable.
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