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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Investigation into the affairs of the appellant company - The matter is only at the stage of investigation and otherwise also the appellant company has not been able to point out the prejudice caused to the appellant company in the matter. The respondents have adopted a transparent process. They have given an opportunity of hearing to the appellant company right from initial stages and the respondents are under obligation to follow the procedure prescribed under Section 212 of the Companies Act and the Companies Act is a complete code in itself. - HC
Investigation into the affairs of the appellant company - The matter is only at the stage of investigation and otherwise also the appellant company has not been able to point out the prejudice caused to the appellant company in the matter. The respondents have adopted a transparent process. They have given an opportunity of hearing to the appellant company right from initial stages and the respondents are under obligation to follow the procedure prescribed under Section 212 of the Companies Act and the Companies Act is a complete code in itself. - HC
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