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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NCLAT held that the transaction between parties was a sale and purchase of assets, not a financial debt under Section 5(8) of Insolvency and Bankruptcy Code. The amounts transferred were for asset consideration, not disbursed for time value of money. The mere inclusion of 2% monthly interest does not transform the transaction into a financial debt. Consequently, the Adjudicating Authority's order admitting the Section 7 application was set aside, and the Corporate Insolvency Resolution Process against the Corporate Debtor was closed.
NCLAT held that the transaction between parties was a sale and purchase of assets, not a financial debt under Section 5(8) of Insolvency and Bankruptcy Code. The amounts transferred were for asset consideration, not disbursed for time value of money. The mere inclusion of 2% monthly interest does not transform the transaction into a financial debt. Consequently, the Adjudicating Authority's order admitting the Section 7 application was set aside, and the Corporate Insolvency Resolution Process against the Corporate Debtor was closed.
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