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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Reassessment proceedings against company insolvent/dissolved - The court held that any tax notices for hearing appeals related to reassessment orders issued after the approval of the resolution plan should be considered void. This is because such proceedings would lapse and could not be sustained under the IBC framework. The court reaffirmed the principle that the approval of a resolution plan under the IBC results in the extinguishment of all claims not included in the plan.
Reassessment proceedings against company insolvent/dissolved - The court held that any tax notices for hearing appeals related to reassessment orders issued after the approval of the resolution plan should be considered void. This is because such proceedings would lapse and could not be sustained under the IBC framework. The court reaffirmed the principle that the approval of a resolution plan under the IBC results in the extinguishment of all claims not included in the plan.
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