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 BankruptcyApril 26, 2024Case LawsAT
Liquidation of the Corporate Debtor - Application seeking extension of timeline for making the payments under the approved Resolution Plan dismissed - The tribunal found that extending payment deadlines does not constitute a modification of the resolution plan but is rather an accommodation to ensure its successful implementation. The tribunal thus set aside the lower court's decision and granted the extension for payment of the fourth and fifth tranches until a specified future date. - The tribunal emphasized that the creditor should adopt a collaborative approach to facilitate the resolution process rather than focusing solely on liquidation.
Liquidation of the Corporate Debtor - Application seeking extension of timeline for making the payments under the approved Resolution Plan dismissed - The tribunal found that extending payment deadlines does not constitute a modification of the resolution plan but is rather an accommodation to ensure its successful implementation. The tribunal thus set aside the lower court's decision and granted the extension for payment of the fourth and fifth tranches until a specified future date. - The tribunal emphasized that the creditor should adopt a collaborative approach to facilitate the resolution process rather than focusing solely on liquidation.
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