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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Mortgage of property - execution of guarantee deeds of the retired director - There is no occasion for the Bank to plead that although the new directors and surety executed the personal guarantee bonds dated 22nd July, 1995 and an immovable property worth much more than the value of loan/limits was given in mortgage, still earlier personal guarantee bonds executed by two erstwhile Directors and Petitioner No.2 are still in force
Mortgage of property - execution of guarantee deeds of the retired director - There is no occasion for the Bank to plead that although the new directors and surety executed the personal guarantee bonds dated 22nd July, 1995 and an immovable property worth much more than the value of loan/limits was given in mortgage, still earlier personal guarantee bonds executed by two erstwhile Directors and Petitioner No.2 are still in force
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