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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CIRP - Classification of the claim - Claim as contingent due to pending litigation - Citing legal precedent, the Tribunal upheld the classification of the claim at a notional value of Rs. 1. - The Tribunal found that the resolution plan's payout prioritized secured financial creditors, leaving nothing for operational creditors. Considering the waterfall mechanism outlined in Section 53 of the Code, the Tribunal determined that operational creditors would receive NIL payment. The Tribunal noted that the CoC's approval of the resolution plan was based on commercial wisdom, which it couldn't interfere with.
CIRP - Classification of the claim - Claim as contingent due to pending litigation - Citing legal precedent, the Tribunal upheld the classification of the claim at a notional value of Rs. 1. - The Tribunal found that the resolution plan's payout prioritized secured financial creditors, leaving nothing for operational creditors. Considering the waterfall mechanism outlined in Section 53 of the Code, the Tribunal determined that operational creditors would receive NIL payment. The Tribunal noted that the CoC's approval of the resolution plan was based on commercial wisdom, which it couldn't interfere with.
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