Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
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...
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Official Liquidator claims arising on a winding-up order remain maintainable if the underlying claim was legally enforceable when winding-up commenced. Limitation runs for three years from the winding-up order under Article 137, while the applicable exclusion for winding-up proceedings and the additional year allowed under the Companies Act produce an aggregate four-year period. A Company Claim instituted within that period is not time-barred, and the preliminary limitation objection fails.
Official Liquidator claims arising on a winding-up order remain maintainable if the underlying claim was legally enforceable when winding-up commenced. Limitation runs for three years from the winding-up order under Article 137, while the applicable exclusion for winding-up proceedings and the additional year allowed under the Companies Act produce an aggregate four-year period. A Company Claim instituted within that period is not time-barred, and the preliminary limitation objection fails.
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