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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Recovery of time-barred debt - The Supreme Court reiterated that the Limitation Act only bars the remedy but does not extinguish the debt, aligning with precedents set in earlier Supreme Court judgments. - The judgment highlighted that specific recovery statutes are designed to operate independently of the Limitation Act, providing an alternative recovery mechanism that does not conform to the standard limitations period. - The Court seeks an authoritative pronouncement on these matters to ensure uniformity and clarity in the application of these laws, recognizing that such decisions could have wide-reaching effects on the legal and financial systems. - Matter placed before the Chief Justice to constitute an appropriate three-judge bench.
Recovery of time-barred debt - The Supreme Court reiterated that the Limitation Act only bars the remedy but does not extinguish the debt, aligning with precedents set in earlier Supreme Court judgments. - The judgment highlighted that specific recovery statutes are designed to operate independently of the Limitation Act, providing an alternative recovery mechanism that does not conform to the standard limitations period. - The Court seeks an authoritative pronouncement on these matters to ensure uniformity and clarity in the application of these laws, recognizing that such decisions could have wide-reaching effects on the legal and financial systems. - Matter placed before the Chief Justice to constitute an appropriate three-judge bench.
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