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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Insolvency and BankruptcyMarch 13, 2020Case LawsTri
CIRP Process - apprehension is that "Telecom Licenses" and grant of "Spectrum" may be terminated during the 'Moratorium' Period because the Debtor Company had defaulted in payment of annual installments - admittedly the License/Spectrum is an asset of State over which the Corporate Debtor has no right of ownership, therefore, up to this extent the argument of the Government is hereby accepted. - But interruption in the CIRP proceedings not allowed - Tri
CIRP Process - apprehension is that "Telecom Licenses" and grant of "Spectrum" may be terminated during the 'Moratorium' Period because the Debtor Company had defaulted in payment of annual installments - admittedly the License/Spectrum is an asset of State over which the Corporate Debtor has no right of ownership, therefore, up to this extent the argument of the Government is hereby accepted. - But interruption in the CIRP proceedings not allowed - Tri
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