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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In a dispute over enhanced share valuation sold to the State of Rajasthan, the SC modified the High Court's judgment regarding interest rates. The Court determined that although the transaction was commercial, it involved the State with superior bargaining power, and the originally offered price was unconscionable. In the absence of any agreement regarding interest for delayed payment, the Court applied Section 34 of the CPC. The SC awarded simple interest at 6% per annum from July 8, 1975, until the date of decree, and 9% per annum thereafter until realization. The Court directed payment of the enhanced share value with applicable interest, after adjusting amounts already paid, within two months.
In a dispute over enhanced share valuation sold to the State of Rajasthan, the SC modified the High Court's judgment regarding interest rates. The Court determined that although the transaction was commercial, it involved the State with superior bargaining power, and the originally offered price was unconscionable. In the absence of any agreement regarding interest for delayed payment, the Court applied Section 34 of the CPC. The SC awarded simple interest at 6% per annum from July 8, 1975, until the date of decree, and 9% per annum thereafter until realization. The Court directed payment of the enhanced share value with applicable interest, after adjusting amounts already paid, within two months.
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