https://www.taxtmi.com/caselaws?id=787911 Under the bilateral MOU and implementing Guidelines, TMO maintains the online registration portal and performs initial contract registration, while CBN verifies and processes only contracts reflected on that portal. CBN has no stated duty to register contracts not uploaded by TMO or to supervise TMO's internal procedures. Country-cap allocation concerns economic policy and an international arrangement; a constitutional challenge requires material showing mala fides, manifest arbitrariness, discrimination, or an enforceable legitimate expectation. Non-uploading by TMO, without such material against CBN, does not establish a breach of Articles 14 or 19(1)(g). en-us Thu, 12 Mar 2026 00:00:00 +0530 Sat, 14 Mar 2026 08:36:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=787911 Under the bilateral MOU and implementing Guidelines, TMO maintains the online registration portal and performs initial contract registration, while CBN verifies and processes only contracts reflected on that portal. CBN has no stated duty to register contracts not uploaded by TMO or to supervise TMO's internal procedures. Country-cap allocation concerns economic policy and an international arrangement; a constitutional challenge requires material showing mala fides, manifest arbitrariness, discrimination, or an enforceable legitimate expectation. Non-uploading by TMO, without such material against CBN, does not establish a breach of Articles 14 or 19(1)(g). Case-Laws Customs Thu, 12 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=787911