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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The SC held that the appellant and Vindas-Respondent No. 3 constitute a single integrated unit under the EPF Act from September 1995, based on factors including unity of ownership, management, finance, and functional integrality. Consequently, the appellant is not entitled to infancy protection under the erstwhile Section 16(1)(d). The Court rejected the appellant's contention that dues could only be demanded from April 2004, affirming that contributions are payable from September 1995. The argument that notice of clubbing should have been issued to Vindas-Respondent No. 3 was also dismissed, as contributions were assessed only for employees of the respective units, with Vindas-Respondent No. 3 already covered. The appeal was found to be devoid of merit and was accordingly dismissed.
The SC held that the appellant and Vindas-Respondent No. 3 constitute a single integrated unit under the EPF Act from September 1995, based on factors including unity of ownership, management, finance, and functional integrality. Consequently, the appellant is not entitled to infancy protection under the erstwhile Section 16(1)(d). The Court rejected the appellant's contention that dues could only be demanded from April 2004, affirming that contributions are payable from September 1995. The argument that notice of clubbing should have been issued to Vindas-Respondent No. 3 was also dismissed, as contributions were assessed only for employees of the respective units, with Vindas-Respondent No. 3 already covered. The appeal was found to be devoid of merit and was accordingly dismissed.
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