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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Preferential Creditor vs Secured Creditor - Provisions of Section 529-A of Companies Act (a Central legislation) have to be override the provisions of Sec 53 of the M.P. Commercial Tax Act of 1994 (a State legislation) - tax liability will be subject to the provisions of Sec 530 of the Companies Act subject to the provisions of Section 529-A of the said Act. - HC
Preferential Creditor vs Secured Creditor - Provisions of Section 529-A of Companies Act (a Central legislation) have to be override the provisions of Sec 53 of the M.P. Commercial Tax Act of 1994 (a State legislation) - tax liability will be subject to the provisions of Sec 530 of the Companies Act subject to the provisions of Section 529-A of the said Act. - HC
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