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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Seeking restoration of petition, which was dismissed for non prosecution - The appellate tribunal acknowledges the assignment agreement between Bank of Baroda and the appellant, which transferred the debt along with all associated rights and interests. The tribunal finds that the assignment was duly recorded and brought to the attention of the adjudicating authority. - The tribunal observes that the appellant took proactive steps to protect its interests, including filing a substitution application and subsequently the restoration application. Despite some procedural delays, the tribunal finds no evidence of negligence or wilful inaction on the part of the appellant.
Seeking restoration of petition, which was dismissed for non prosecution - The appellate tribunal acknowledges the assignment agreement between Bank of Baroda and the appellant, which transferred the debt along with all associated rights and interests. The tribunal finds that the assignment was duly recorded and brought to the attention of the adjudicating authority. - The tribunal observes that the appellant took proactive steps to protect its interests, including filing a substitution application and subsequently the restoration application. Despite some procedural delays, the tribunal finds no evidence of negligence or wilful inaction on the part of the appellant.
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