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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NCLAT dismissed appellant's challenge to Section 95 application initiating Personal Insolvency Resolution Process. Appellant contended notice invoking bank guarantee dated 10.10.2017 was never served, constituting violation of natural justice principles. NCLAT found materials on record from SBI and Resolution Professional established proper service of guarantee invocation notice and legal demand notice via speed post. Court noted appellant failed to file replies despite repeated opportunities before Adjudicating Authority and never raised non-service argument during oral submissions. NCLAT concluded notice invoking bank guarantee was duly served, rejecting appellant's contentions as meritless and dismissing the appeal entirely.
NCLAT dismissed appellant's challenge to Section 95 application initiating Personal Insolvency Resolution Process. Appellant contended notice invoking bank guarantee dated 10.10.2017 was never served, constituting violation of natural justice principles. NCLAT found materials on record from SBI and Resolution Professional established proper service of guarantee invocation notice and legal demand notice via speed post. Court noted appellant failed to file replies despite repeated opportunities before Adjudicating Authority and never raised non-service argument during oral submissions. NCLAT concluded notice invoking bank guarantee was duly served, rejecting appellant's contentions as meritless and dismissing the appeal entirely.
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