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 dismissed plaintiff's challenge to defendants' Expression of Interest notice for debt assignment, holding plaintiff lacked locus standi having filed suit on same day EoI was published without submitting bid. Court found no lack of transparency as EoI clearly stated shortlisted bidders would access bid documents and virtual data room before final binding bids, making challenge premature. Swiss Challenge method deemed transparent per Ravi Development precedent as all parties aware of originator's right of first refusal. No RBI Master Circular violation established since plaintiff failed to participate in process to access relevant information for proper assessment. Court noted appellant NBFC bound by RBI regulations regardless of government entity status. Suit held prima facie not maintainable with no irreparable injury demonstrated.
HC dismissed plaintiff's challenge to defendants' Expression of Interest notice for debt assignment, holding plaintiff lacked locus standi having filed suit on same day EoI was published without submitting bid. Court found no lack of transparency as EoI clearly stated shortlisted bidders would access bid documents and virtual data room before final binding bids, making challenge premature. Swiss Challenge method deemed transparent per Ravi Development precedent as all parties aware of originator's right of first refusal. No RBI Master Circular violation established since plaintiff failed to participate in process to access relevant information for proper assessment. Court noted appellant NBFC bound by RBI regulations regardless of government entity status. Suit held prima facie not maintainable with no irreparable injury demonstrated.
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