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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Allegations of professional misconduct against counsel for filing an appeal on oral/client instructions were rejected because the record showed no misconduct and the filing was under bona fide instructions; consequently, no direction for payment of 18% interest or litigation costs was warranted on that basis. The appellate order dismissing the underlying appeal for non-rectification of defects under Rule 26(3)-(4) was affirmed, and the proceeding was closed. In view of frivolous and false imputations that undermine the legal profession, liberty was reserved to the affected counsel to initiate criminal proceedings for malicious prosecution against the appellant. - NCLAT
Allegations of professional misconduct against counsel for filing an appeal on oral/client instructions were rejected because the record showed no misconduct and the filing was under bona fide instructions; consequently, no direction for payment of 18% interest or litigation costs was warranted on that basis. The appellate order dismissing the underlying appeal for non-rectification of defects under Rule 26(3)-(4) was affirmed, and the proceeding was closed. In view of frivolous and false imputations that undermine the legal profession, liberty was reserved to the affected counsel to initiate criminal proceedings for malicious prosecution against the appellant. - NCLAT
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