TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Forfeiture of a successful bidder's part payment before expiry of an expressly extended period for paying the auction balance is arbitrary. A payment communication allowing payment beyond the original deadline with interest for up to 60 days made forfeiture operative only upon default continuing after that period. Discretion under the payment schedule to extend the timeline and the regulatory framework for delayed payment with interest did not permit earlier cancellation or forfeiture. Where the asset was subsequently sold and consideration realised, retention of the part payment was unjustified. The forfeiture was set aside to the extent of refunding the part payment without interest.
Forfeiture of a successful bidder's part payment before expiry of an expressly extended period for paying the auction balance is arbitrary. A payment communication allowing payment beyond the original deadline with interest for up to 60 days made forfeiture operative only upon default continuing after that period. Discretion under the payment schedule to extend the timeline and the regulatory framework for delayed payment with interest did not permit earlier cancellation or forfeiture. Where the asset was subsequently sold and consideration realised, retention of the part payment was unjustified. The forfeiture was set aside to the extent of refunding the part payment without interest.
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