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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
The NCLAT partly allowed the appeal, setting aside the NCLT's limited interest award as unsupportable and holding the respondents liable for simple interest at 6% per annum from 16.04.2010 until the date the disputed sum of Rs.285 lakh was deposited. The Tribunal declined to increase the rate to 18% sought by the appellant, citing the significant lapse of time, but found that the respondents breached the 08.09.2009 settlement and were at fault from 15.04.2010 for failing to pay or duly perform even by proposed instalments. The impugned award of interest only for 07.01.2022-28.02.2023 was set aside. Appeal disposed.
The NCLAT partly allowed the appeal, setting aside the NCLT's limited interest award as unsupportable and holding the respondents liable for simple interest at 6% per annum from 16.04.2010 until the date the disputed sum of Rs.285 lakh was deposited. The Tribunal declined to increase the rate to 18% sought by the appellant, citing the significant lapse of time, but found that the respondents breached the 08.09.2009 settlement and were at fault from 15.04.2010 for failing to pay or duly perform even by proposed instalments. The impugned award of interest only for 07.01.2022-28.02.2023 was set aside. Appeal disposed.
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