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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SC ruled that a General Power of Attorney (GPA) holder's concurrent possession of an Agreement to Sell does not automatically confer interest in the immovable property. The court emphasized that even contemporaneous execution of GPA and Agreement to Sell cannot establish the holder's interest without proper registration under Section 17(1)(b) of the Registration Act. The relationship between GPA executant and holder remains strictly principal-agent as per Contract Act principles. The mere labeling of GPA as 'irrevocable' does not make it so unless coupled with interest. The court dismissed the appeal, affirming that unregistered documents cannot create valid right, title, or interest in immovable property, thereby discouraging property transfers through GPA and Agreement to Sell route.
SC ruled that a General Power of Attorney (GPA) holder's concurrent possession of an Agreement to Sell does not automatically confer interest in the immovable property. The court emphasized that even contemporaneous execution of GPA and Agreement to Sell cannot establish the holder's interest without proper registration under Section 17(1)(b) of the Registration Act. The relationship between GPA executant and holder remains strictly principal-agent as per Contract Act principles. The mere labeling of GPA as 'irrevocable' does not make it so unless coupled with interest. The court dismissed the appeal, affirming that unregistered documents cannot create valid right, title, or interest in immovable property, thereby discouraging property transfers through GPA and Agreement to Sell route.
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