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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Validity of order of Adjudicating authority (NCLT) observations against the IRP to refer the matter to IBBI. - Order of NCLT relies more on uploading of the Order on website, rather than finding if or not the Order was actually communicated to parties and IRP. Admission Order para 11 even mentioned e-mail address of IRP. Communication could have been sent even on e-mail. - Therefore no fault on the part of IRP for not having knowledge of order of NCLT - Paragraphs 24 and 25 of the Impugned Order set aside - AT
Validity of order of Adjudicating authority (NCLT) observations against the IRP to refer the matter to IBBI. - Order of NCLT relies more on uploading of the Order on website, rather than finding if or not the Order was actually communicated to parties and IRP. Admission Order para 11 even mentioned e-mail address of IRP. Communication could have been sent even on e-mail. - Therefore no fault on the part of IRP for not having knowledge of order of NCLT - Paragraphs 24 and 25 of the Impugned Order set aside - AT
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