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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Fresh claim after CIRP proceedings - The CIRP is a time-bound process and if the Adjudicating Authority sets the clock back for the reason that the Applicant was not diligent enough in pursuing its claim, it would certainly go against the main objective of the Code - It is wrong on the part of the Applicant to submit that the RP has himself caused unnecessary delay in consideration of the claim of the Applicant, that had been filed even before the Resolution Plan was received by the RP. - Tri
Fresh claim after CIRP proceedings - The CIRP is a time-bound process and if the Adjudicating Authority sets the clock back for the reason that the Applicant was not diligent enough in pursuing its claim, it would certainly go against the main objective of the Code - It is wrong on the part of the Applicant to submit that the RP has himself caused unnecessary delay in consideration of the claim of the Applicant, that had been filed even before the Resolution Plan was received by the RP. - Tri
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