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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No action having ever been initiated by the APIIC to raise a dispute as to its liability to pay the amount aforestated or as to delayed discharge of contractual obligations by the company petitioner, it is too late in the day for it to now raise the ruse of a bonafide dispute to ward off the summary proceedings initiated under the Act of 1956 for its winding up. - HC
No action having ever been initiated by the APIIC to raise a dispute as to its liability to pay the amount aforestated or as to delayed discharge of contractual obligations by the company petitioner, it is too late in the day for it to now raise the ruse of a bonafide dispute to ward off the summary proceedings initiated under the Act of 1956 for its winding up. - HC
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