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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Proceedings in NCLT - part physical and part virtual hearing - infringement of Fundamental Rights - if the Tribunal wants to go for physical hearing of any particular matter, it may go for it, but, at the same time, it must seek the consent of all the learned counsel appearing in the litigation and only thereafter, it may proceed. However, it should not happen that one set of lawyers would appear before the Tribunal physically and the Tribunal would take up the matter, hear those lawyers and decide the matter without the consent of the other set of lawyers appearing for the different parties. Such practice is bound to create hue and cry. - HC
Proceedings in NCLT - part physical and part virtual hearing - infringement of Fundamental Rights - if the Tribunal wants to go for physical hearing of any particular matter, it may go for it, but, at the same time, it must seek the consent of all the learned counsel appearing in the litigation and only thereafter, it may proceed. However, it should not happen that one set of lawyers would appear before the Tribunal physically and the Tribunal would take up the matter, hear those lawyers and decide the matter without the consent of the other set of lawyers appearing for the different parties. Such practice is bound to create hue and cry. - HC
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