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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Oppression and mismanagement - conduct of due election of the Board of Directors - Lame excuses to conduct the election cannot be accepted for not conducting the election. The Tribunal cannot be a moot spectator in the matter. In order to give an end to the issue involved and in the interest of justice, it is high time to order for conducting the election to the Board of Directors of the 4th Respondent Company in terms of the Articles of Association of the 4th respondent Company. It is not necessary to appoint a Commissioner for the conduct of such an election, as the administrator is competent to conduct the election. - Tri
Oppression and mismanagement - conduct of due election of the Board of Directors - Lame excuses to conduct the election cannot be accepted for not conducting the election. The Tribunal cannot be a moot spectator in the matter. In order to give an end to the issue involved and in the interest of justice, it is high time to order for conducting the election to the Board of Directors of the 4th Respondent Company in terms of the Articles of Association of the 4th respondent Company. It is not necessary to appoint a Commissioner for the conduct of such an election, as the administrator is competent to conduct the election. - Tri
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