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 resolved jurisdictional dispute regarding arbitral proceedings under MSMED Act, affirming Facilitation Council's exclusive jurisdiction where MSME supplier is located. The Court upheld prior precedent in Mahakali case, determining that Section 18(4) of MSMED Act specifically vests arbitration jurisdiction in the council where supplier is domiciled. In this instance, Delhi Facilitation Council was deemed competent to conduct arbitration through Delhi Arbitration Centre. The SC allowed the appeal, set aside the Karnataka HC order, and directed arbitral proceedings to be conducted consistent with statutory mandate.
SC resolved jurisdictional dispute regarding arbitral proceedings under MSMED Act, affirming Facilitation Council's exclusive jurisdiction where MSME supplier is located. The Court upheld prior precedent in Mahakali case, determining that Section 18(4) of MSMED Act specifically vests arbitration jurisdiction in the council where supplier is domiciled. In this instance, Delhi Facilitation Council was deemed competent to conduct arbitration through Delhi Arbitration Centre. The SC allowed the appeal, set aside the Karnataka HC order, and directed arbitral proceedings to be conducted consistent with statutory mandate.
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