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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Liquidator's discretion in fixing reserve price upheld. COVID-19 lockdown considered valid reason for extension to deposit balance sale consideration. Allegation of undervaluation rejected as appellant failed to bring higher bidders despite opportunities. Non-constitution of Stakeholders' Consultation Committee not violative due to clarificatory explanation. Regulation 33 considered directory, Adjudicating Authority's extension of time justified under extraordinary circumstances. Attachment order no ground to deny balance payment, purchaser's due diligence obligatory. Cancellation of sale refused considering purchaser's investments, appellant's delayed objections. Additional amount imposed on purchaser to balance equities.
Liquidator's discretion in fixing reserve price upheld. COVID-19 lockdown considered valid reason for extension to deposit balance sale consideration. Allegation of undervaluation rejected as appellant failed to bring higher bidders despite opportunities. Non-constitution of Stakeholders' Consultation Committee not violative due to clarificatory explanation. Regulation 33 considered directory, Adjudicating Authority's extension of time justified under extraordinary circumstances. Attachment order no ground to deny balance payment, purchaser's due diligence obligatory. Cancellation of sale refused considering purchaser's investments, appellant's delayed objections. Additional amount imposed on purchaser to balance equities.
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