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...
Pre-existing disputes concerning the genuineness of purchase orders, supplies and underlying operational-debt transactions prevent corporate insolvency resolution proceedings from being used to determine contested claims. Information Utility records marked the debt as disputed, while the corporate debtor's legal notice and fraud-related complaints pre-dated the demand notice. As the dispute was neither spurious nor illusory and required detailed trial, a Section 9 application was not maintainable for adjudicating it. Rejection of the operational creditor's insolvency application was therefore sustained, and the appeal was dismissed.
Pre-existing disputes concerning the genuineness of purchase orders, supplies and underlying operational-debt transactions prevent corporate insolvency resolution proceedings from being used to determine contested claims. Information Utility records marked the debt as disputed, while the corporate debtor's legal notice and fraud-related complaints pre-dated the demand notice. As the dispute was neither spurious nor illusory and required detailed trial, a Section 9 application was not maintainable for adjudicating it. Rejection of the operational creditor's insolvency application was therefore sustained, and the appeal was dismissed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4888 
