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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Forensic audit was ordered to trace the dissipation of promoter shareholding and other assets represented as available to satisfy a foreign arbitral award. Conflicting accounts concerning share transfers, loans, pledges, top-up arrangements, encumbrances, and use of proceeds required factual reconstruction rather than resolution on existing material. The audit extends to concerned entities, banks and financial institutions, notwithstanding the decree holder's later request to exclude banks, because they may have assisted in breach of court orders. Separate corporate personality does not prevent examination of a listed company's possible knowledge, facilitation, and regulatory compliance where common controllers may have used the structure to frustrate execution. The audit determines no present liability; consequential issues remain open.
Forensic audit was ordered to trace the dissipation of promoter shareholding and other assets represented as available to satisfy a foreign arbitral award. Conflicting accounts concerning share transfers, loans, pledges, top-up arrangements, encumbrances, and use of proceeds required factual reconstruction rather than resolution on existing material. The audit extends to concerned entities, banks and financial institutions, notwithstanding the decree holder's later request to exclude banks, because they may have assisted in breach of court orders. Separate corporate personality does not prevent examination of a listed company's possible knowledge, facilitation, and regulatory compliance where common controllers may have used the structure to frustrate execution. The audit determines no present liability; consequential issues remain open.
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