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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HC validated the sale and transfer of 234,000 equity shares based on a pre-existing contractual agreement. The Applicants exercised an irrevocable call option under the MOU after the company's failure to infuse agreed funds. The court determined that the transaction was bona fide, initiated prior to winding up proceedings, and completed in accordance with crystallized contractual rights. Applying Section 536(2) of the Companies Act, 1956, the court ratified the share transfer, recognizing that strict interpretation could potentially paralyze business operations during liquidation proceedings. The application was ultimately allowed, affirming the Applicants' right to complete the share transfer.
HC validated the sale and transfer of 234,000 equity shares based on a pre-existing contractual agreement. The Applicants exercised an irrevocable call option under the MOU after the company's failure to infuse agreed funds. The court determined that the transaction was bona fide, initiated prior to winding up proceedings, and completed in accordance with crystallized contractual rights. Applying Section 536(2) of the Companies Act, 1956, the court ratified the share transfer, recognizing that strict interpretation could potentially paralyze business operations during liquidation proceedings. The application was ultimately allowed, affirming the Applicants' right to complete the share transfer.
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