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...
Annulment of a securities trade ends the transaction and makes subsequent physical delivery of the shares purposeless where the shares have been returned to the selling member. The purchaser is entitled to recover the purchase consideration with interest from the Exchange, rather than pursue trading-loss damages. The selling member is not a necessary party because the settlement mechanism creates no direct buyer-seller contract requiring relief against that member after annulment; arbitration and closing-out remedies are therefore inapplicable. An indemnity limited to dispute-resolution references does not grant the Exchange general immunity, and Clearing House non-liability provisions concerning title or validity of securities do not bar refund liability arising from annulment.
Annulment of a securities trade ends the transaction and makes subsequent physical delivery of the shares purposeless where the shares have been returned to the selling member. The purchaser is entitled to recover the purchase consideration with interest from the Exchange, rather than pursue trading-loss damages. The selling member is not a necessary party because the settlement mechanism creates no direct buyer-seller contract requiring relief against that member after annulment; arbitration and closing-out remedies are therefore inapplicable. An indemnity limited to dispute-resolution references does not grant the Exchange general immunity, and Clearing House non-liability provisions concerning title or validity of securities do not bar refund liability arising from annulment.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4899 
