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 - minority shareholders - There was no alternative except liquidation or revival of company through other modes including sale of assets to other entity who could revive the company - not taking consent of the Appellants cannot be construed as act of oppression by majority shareholders especially keeping in view that the sale of the assets of the company was for the benefits of all stakeholders including shareholders and the company itself. - AT
Oppression and Mismanagement - minority shareholders - There was no alternative except liquidation or revival of company through other modes including sale of assets to other entity who could revive the company - not taking consent of the Appellants cannot be construed as act of oppression by majority shareholders especially keeping in view that the sale of the assets of the company was for the benefits of all stakeholders including shareholders and the company itself. - AT
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