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 appeals, upholding the adjudicating authority's rejection under s.114(1) of the I&B Code of the appellants' repayment plan(s) for personal guarantors. The Tribunal found no evidence of a group insolvency process, recorded an apparent failure by the appellants to furnish the modified repayment plan within prescribed timeframes after meetings on 29.11.2022 and 01.12.2022, and held that denial of revision under s.115 did not disclose any manifest error warranting interference. Subsequent initiation of proceedings under s.123 and the declaration of corporate guarantors' bankruptcy on 18.04.2024 further rendered the limited challenge to the repayment-plan rejection devoid of practical relief.
The NCLAT dismissed the appeals, upholding the adjudicating authority's rejection under s.114(1) of the I&B Code of the appellants' repayment plan(s) for personal guarantors. The Tribunal found no evidence of a group insolvency process, recorded an apparent failure by the appellants to furnish the modified repayment plan within prescribed timeframes after meetings on 29.11.2022 and 01.12.2022, and held that denial of revision under s.115 did not disclose any manifest error warranting interference. Subsequent initiation of proceedings under s.123 and the declaration of corporate guarantors' bankruptcy on 18.04.2024 further rendered the limited challenge to the repayment-plan rejection devoid of practical relief.
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