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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AT directed the appellants to refund monies to 1,100 investors who approached them, granting a reduced rate of interest of 9% per annum in lieu of the prayed 12%. The Tribunal found the land rendered unusable by oil spillage, preventing the cultivation of promised teak saplings and noting investors' delay of approximately three decades. In the exercise of equitable discretion and in the interests of justice, the claim for refund was allowed subject to the reduced rate; appellants were ordered to make restitution to the identified investors at 9% p.a., thereby resolving the dispute without compelling performance of the original prospectus benefits.
AT directed the appellants to refund monies to 1,100 investors who approached them, granting a reduced rate of interest of 9% per annum in lieu of the prayed 12%. The Tribunal found the land rendered unusable by oil spillage, preventing the cultivation of promised teak saplings and noting investors' delay of approximately three decades. In the exercise of equitable discretion and in the interests of justice, the claim for refund was allowed subject to the reduced rate; appellants were ordered to make restitution to the identified investors at 9% p.a., thereby resolving the dispute without compelling performance of the original prospectus benefits.
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