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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Purchase of property - Genuineness of transaction - The transaction as alleged by the applicant is not a bona fide act. The conclusions of the Thareja Committee is concurred with - Further, in 2002 when the alleged transaction took place, the JVG Group of Companies was a sinking ship. The flagship company of the Group, namely, JVG Finance Ltd. had already been ordered to be provisionally wound up by order dated 05.06.1998. One cannot help coming to the conclusion that this transaction was carried out only to whisk away valuable assets of the JVG Group of Companies which at that time were likely to go under winding up proceedings. - HC
Purchase of property - Genuineness of transaction - The transaction as alleged by the applicant is not a bona fide act. The conclusions of the Thareja Committee is concurred with - Further, in 2002 when the alleged transaction took place, the JVG Group of Companies was a sinking ship. The flagship company of the Group, namely, JVG Finance Ltd. had already been ordered to be provisionally wound up by order dated 05.06.1998. One cannot help coming to the conclusion that this transaction was carried out only to whisk away valuable assets of the JVG Group of Companies which at that time were likely to go under winding up proceedings. - HC
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