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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The HC dismissed an application seeking validation of an unregistered sale agreement under Section 536(2) of the Companies Act, 1956. The Court determined that the agreement was "incomplete and inchoate" as the applicant failed to pay stamp duty or register the document despite being contractually obligated to do so as the transferee. The Court rejected the applicant's reliance on Section 53A of the Transfer of Property Act due to lack of registration as required by Section 17(1A) of the Registration Act. While not ruling against the applicant on grounds of delay, the Court upheld the Official Liquidator's report and directed the applicant to surrender possession of the subject property to the Official Liquidator.
The HC dismissed an application seeking validation of an unregistered sale agreement under Section 536(2) of the Companies Act, 1956. The Court determined that the agreement was "incomplete and inchoate" as the applicant failed to pay stamp duty or register the document despite being contractually obligated to do so as the transferee. The Court rejected the applicant's reliance on Section 53A of the Transfer of Property Act due to lack of registration as required by Section 17(1A) of the Registration Act. While not ruling against the applicant on grounds of delay, the Court upheld the Official Liquidator's report and directed the applicant to surrender possession of the subject property to the Official Liquidator.
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