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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Condonation of delay in filing of Review Application - In view of the fact that Section 14 of the Limitation Act, 1963 applies to the Court / Tribunal whether the exclusion of time bonafide in Court / Tribunal without jurisdiction and in the instant Case, Review Application was filed before the National Company Law Tribunal, Division Bench-II, Chennai to review an earlier, by no stretch of imagination, be said to be Tribunal possessing no jurisdiction, viewed in that light, the invocation of Section 14 of the Limitation Act, 1963 on behalf of the Applicant / Appellant sans merits. - AT
Condonation of delay in filing of Review Application - In view of the fact that Section 14 of the Limitation Act, 1963 applies to the Court / Tribunal whether the exclusion of time bonafide in Court / Tribunal without jurisdiction and in the instant Case, Review Application was filed before the National Company Law Tribunal, Division Bench-II, Chennai to review an earlier, by no stretch of imagination, be said to be Tribunal possessing no jurisdiction, viewed in that light, the invocation of Section 14 of the Limitation Act, 1963 on behalf of the Applicant / Appellant sans merits. - AT
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