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 BankruptcyApril 30, 2022Case LawsAT
Initiation of CIRP - Application barred by time limitation or not - The acknowledgement made by the Principal Borrower within three years’ period from the date of account being declared NPA, there shall be fresh period of limitation available to the Financial Creditor and the Application under Section 7 having been filed within three years from the date of acknowledgement, cannot be held to be barred by time - the Application filed by the State Bank of India under Section 7 was within the period of limitation and has rightly been admitted by the Adjudicating Authority. - AT
Initiation of CIRP - Application barred by time limitation or not - The acknowledgement made by the Principal Borrower within three years’ period from the date of account being declared NPA, there shall be fresh period of limitation available to the Financial Creditor and the Application under Section 7 having been filed within three years from the date of acknowledgement, cannot be held to be barred by time - the Application filed by the State Bank of India under Section 7 was within the period of limitation and has rightly been admitted by the Adjudicating Authority. - AT
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