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 NCLAT dismissed the appeal and upheld the impugned order directing the Appellant to deliver the title deeds to the Liquidator. The Tribunal held the Appellant lacked any sustainable proprietary or equitable-mortgage rights because the material Memorandum of Deposit of Title Deed (MoDT) dated 30.12.2020 was unregistered and therefore inadmissible and ineffective under Section 17 read with the State amendment and barred from evidence by Section 49 of the Registration Act; the registered Agreement for Sale alone did not confer an enforceable right in the absence of specific-performance proceedings and the Appellant's failure to lodge a claim with the Liquidator.
The NCLAT dismissed the appeal and upheld the impugned order directing the Appellant to deliver the title deeds to the Liquidator. The Tribunal held the Appellant lacked any sustainable proprietary or equitable-mortgage rights because the material Memorandum of Deposit of Title Deed (MoDT) dated 30.12.2020 was unregistered and therefore inadmissible and ineffective under Section 17 read with the State amendment and barred from evidence by Section 49 of the Registration Act; the registered Agreement for Sale alone did not confer an enforceable right in the absence of specific-performance proceedings and the Appellant's failure to lodge a claim with the Liquidator.
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