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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NCLAT dismissed the appeals and upheld the sanctioning order, holding that the Appellant lacks statutory standing under Section 230(4) of the Act (fails the 10% threshold) and therefore is not an "aggrieved person" under Section 421. The Tribunal found no illegality in the sanction process or in the Scheme's terms, noting the Impugned Order was detailed and reasoned. Despite allegations of unfair valuation, undisclosed regulatory relaxations, undue influence, and participation by related employees and funds, NCLAT concluded these contentions do not warrant setting aside the order. With 93.82% equity and 71.89% public shareholder approval, the appeals were dismissed and the Scheme's sanction remains intact, implementation only delayed by the Appellant's minimal holding.
NCLAT dismissed the appeals and upheld the sanctioning order, holding that the Appellant lacks statutory standing under Section 230(4) of the Act (fails the 10% threshold) and therefore is not an "aggrieved person" under Section 421. The Tribunal found no illegality in the sanction process or in the Scheme's terms, noting the Impugned Order was detailed and reasoned. Despite allegations of unfair valuation, undisclosed regulatory relaxations, undue influence, and participation by related employees and funds, NCLAT concluded these contentions do not warrant setting aside the order. With 93.82% equity and 71.89% public shareholder approval, the appeals were dismissed and the Scheme's sanction remains intact, implementation only delayed by the Appellant's minimal holding.
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