Attachment and proclamation of sale of immovable property: limitation treated from financial year end; proclamation held within period, petition dismi...
Second Schedule attachment and validity of a post-notice mortgage: TRO cannot declare mortgage void ab initio; sale and appropriation allowed thereaft...
Limitation for final assessment under sections 144C and 153 treated jointly, resulting in quashing of timebarred assessment order and liberty to reviv...
Deductibility of settlement payments for securities law penalties and treatment of unexplained cash credits in share trading -- Tribunal upholds posit...
Threshold for allottee-initiated insolvency petitions in leasehold real estate upheld; petition admitted after possession letters deemed legally ineff...
Contravention of foreign exchange rules in crossborder diamond payments; appellate tribunal reduces one appellant's penalty for delay and proportional...
Foreign exchange fluctuation arising from international transactions for provision of specified products/services under a cost-plus arrangement was held to be operating in nature, since the gain/loss directly emanated from trading items linked to the controlled transactions; accordingly, treating the foreign exchange loss as non-operating cost for TP computation was impermissible and the adjustment on that basis was set aside. On benchmarking, the challenge to the price applied/proposed in an uncontrolled transaction and the related selection/exclusion of comparables was decided in favour of the assessee, resulting in deletion/relief from the impugned TP adjustments. - HC
Foreign exchange fluctuation arising from international transactions for provision of specified products/services under a cost-plus arrangement was held to be operating in nature, since the gain/loss directly emanated from trading items linked to the controlled transactions; accordingly, treating the foreign exchange loss as non-operating cost for TP computation was impermissible and the adjustment on that basis was set aside. On benchmarking, the challenge to the price applied/proposed in an uncontrolled transaction and the related selection/exclusion of comparables was decided in favour of the assessee, resulting in deletion/relief from the impugned TP adjustments. - HC
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