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 HC dismissed the petition seeking enforcement of a bank guarantee nearly seven years after its expiry and renewal period. The petitioner failed to lodge any claim within the validity period, rendering the belated enforcement attempt untenable. The court interpreted the guarantee clauses in their entirety, finding that reliance solely on the "continuing guarantee" language was misplaced, especially given the non-obstante clause limiting such claims. The petition was deemed an impermissible attempt to enforce a stale contract, and writ jurisdiction was held inappropriate for this purpose. Consequently, the petition lacked merit and was dismissed.
The HC dismissed the petition seeking enforcement of a bank guarantee nearly seven years after its expiry and renewal period. The petitioner failed to lodge any claim within the validity period, rendering the belated enforcement attempt untenable. The court interpreted the guarantee clauses in their entirety, finding that reliance solely on the "continuing guarantee" language was misplaced, especially given the non-obstante clause limiting such claims. The petition was deemed an impermissible attempt to enforce a stale contract, and writ jurisdiction was held inappropriate for this purpose. Consequently, the petition lacked merit and was dismissed.
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