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 allowed the petition and directed condonation of delay under section 119(2)(b) for filing the return of income, holding that refusal would cause genuine hardship and frustrate the NCLT-approved resolution plan. The court found the petitioner assumed management only after approval of the resolution plan, promptly audited accounts and filed returns, and faced administrative impediments including prior non-audit and GST cancellation (later restored). The HC emphasized that denying carry-forward rights would nullify the resolution plan binding on authorities; it did not adjudicate entitlement to losses but granted relief to effectuate the resolution process and avoid genuine hardship to the petitioner.
The HC allowed the petition and directed condonation of delay under section 119(2)(b) for filing the return of income, holding that refusal would cause genuine hardship and frustrate the NCLT-approved resolution plan. The court found the petitioner assumed management only after approval of the resolution plan, promptly audited accounts and filed returns, and faced administrative impediments including prior non-audit and GST cancellation (later restored). The HC emphasized that denying carry-forward rights would nullify the resolution plan binding on authorities; it did not adjudicate entitlement to losses but granted relief to effectuate the resolution process and avoid genuine hardship to the petitioner.
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