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 sanctioned scheme of arrangement assigning specified creditors' claims to the 63 Moons Group was held binding on all specified creditors, including dissenters, because the claims pursued in the civil suits arose from the same NSEL payment default and fell within the scheme. Once the settlement trigger event occurred, those claims, including claims against consenting brokers, stood assigned to the assignee, so the appellants could not continue independent civil proceedings for covered claims. The Tribunal also refused to revisit the scheme's legality, noting that earlier orders upholding it had already attained finality and were affirmed on merits by the Supreme Court. The appeal was dismissed.
A sanctioned scheme of arrangement assigning specified creditors' claims to the 63 Moons Group was held binding on all specified creditors, including dissenters, because the claims pursued in the civil suits arose from the same NSEL payment default and fell within the scheme. Once the settlement trigger event occurred, those claims, including claims against consenting brokers, stood assigned to the assignee, so the appellants could not continue independent civil proceedings for covered claims. The Tribunal also refused to revisit the scheme's legality, noting that earlier orders upholding it had already attained finality and were affirmed on merits by the Supreme Court. The appeal was dismissed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4807 
Join Channel 
