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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AT allowed the appeal against parallel proceedings involving the former MD and CEO of ICICI Bank. The tribunal found potential procedural bias due to the same adjudicating officer handling investigations against both the bank and the appellant. The fundamental principles of fair practice were violated, as the officer was privy to documents from ICICI Bank that could potentially influence the appellant's case. The tribunal directed SEBI to provide the appellant with copies of show cause notices, allow inspection of all bank-related documents, and schedule a fresh hearing, ensuring the appellant's right to a fair defense.
AT allowed the appeal against parallel proceedings involving the former MD and CEO of ICICI Bank. The tribunal found potential procedural bias due to the same adjudicating officer handling investigations against both the bank and the appellant. The fundamental principles of fair practice were violated, as the officer was privy to documents from ICICI Bank that could potentially influence the appellant's case. The tribunal directed SEBI to provide the appellant with copies of show cause notices, allow inspection of all bank-related documents, and schedule a fresh hearing, ensuring the appellant's right to a fair defense.
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