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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Insolvency and BankruptcyMarch 10, 2022Case LawsTri
Initiation of CIRP - On reading the terms of the Joint Development Agreement, it is clear that in the project there are certain things to be done on the part of the petitioner herein - The revenue sharing concept which is the key to, this JVA makes it very clear that it cannot be turned as a service owed by the Respondent to the petitioner; both will have to sail together or sink, because of the JVA. - The dispute on balance / dues to be paid, should at best be termed as an ongoing business liability which should have been resolved between the parties in terms of the JVA. - Tri
Initiation of CIRP - On reading the terms of the Joint Development Agreement, it is clear that in the project there are certain things to be done on the part of the petitioner herein - The revenue sharing concept which is the key to, this JVA makes it very clear that it cannot be turned as a service owed by the Respondent to the petitioner; both will have to sail together or sink, because of the JVA. - The dispute on balance / dues to be paid, should at best be termed as an ongoing business liability which should have been resolved between the parties in terms of the JVA. - Tri
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