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 BankruptcyJanuary 3, 2023Case LawsAT
Initition of CIRP - Ex-parte order - Corporate Debtor could not appear before the NCLT - in the instant case on hand, there is overwhelming evidence of Debt Due, payable in Fact and in Law, and Default, the Adjudicating Authority, had exercised its subjective discretion in a sound, judicious and right thinking manner, and accordingly Admitted the application, filed by the 1st Respondent / Bank(Financial Creditor), which requires no interference, in the hands of this Tribunal, sitting in Appeal. Consequently, the Appeal fails. - AT
Initition of CIRP - Ex-parte order - Corporate Debtor could not appear before the NCLT - in the instant case on hand, there is overwhelming evidence of Debt Due, payable in Fact and in Law, and Default, the Adjudicating Authority, had exercised its subjective discretion in a sound, judicious and right thinking manner, and accordingly Admitted the application, filed by the 1st Respondent / Bank(Financial Creditor), which requires no interference, in the hands of this Tribunal, sitting in Appeal. Consequently, the Appeal fails. - AT
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