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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Anti-Competitive Agreements - Monopoly - abuse of dominant position - principal bone of contention of the appellants is that Coal India Limited, the first appellant (CIL) being a monopoly created by a statute and duty bound to achieve the objects declared in Article 39(b) of the Constitution of India - bound by the Competition Act, 2002 or not - there is no merit in the contention of the appellants that the Act will not apply to the appellants for the reason that the appellants are governed by the Nationalisation Act and that Nationalisation Act cannot be reconciled with the Act. - SC
Anti-Competitive Agreements - Monopoly - abuse of dominant position - principal bone of contention of the appellants is that Coal India Limited, the first appellant (CIL) being a monopoly created by a statute and duty bound to achieve the objects declared in Article 39(b) of the Constitution of India - bound by the Competition Act, 2002 or not - there is no merit in the contention of the appellants that the Act will not apply to the appellants for the reason that the appellants are governed by the Nationalisation Act and that Nationalisation Act cannot be reconciled with the Act. - SC
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