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 modified interim injunction order in loan recovery matter involving Rs. 26 crores debt. While acknowledging petitioner's prima facie case based on respondent's books and admission letter, court found balance of convenience favored vacating bank account restraint requiring Rs. 40 crores minimum balance. Court noted NARCL's control over both parties provided adequate protection. Injunction modified to restrain disposal of disclosed investments and future investments while permitting normal business operations. SARFAESI Act security over scheduled assets deemed sufficient protection. Court emphasized parallel proceedings under SARFAESI Act and Arbitration Act can continue simultaneously. Petitioner retained liberty to seek interim relief before arbitrator. Application disposed with modified interim relief balancing creditor protection against debtor's operational requirements.
HC modified interim injunction order in loan recovery matter involving Rs. 26 crores debt. While acknowledging petitioner's prima facie case based on respondent's books and admission letter, court found balance of convenience favored vacating bank account restraint requiring Rs. 40 crores minimum balance. Court noted NARCL's control over both parties provided adequate protection. Injunction modified to restrain disposal of disclosed investments and future investments while permitting normal business operations. SARFAESI Act security over scheduled assets deemed sufficient protection. Court emphasized parallel proceedings under SARFAESI Act and Arbitration Act can continue simultaneously. Petitioner retained liberty to seek interim relief before arbitrator. Application disposed with modified interim relief balancing creditor protection against debtor's operational requirements.
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