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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Challenge to admission of an insolvency petition founded on a settlement following payment of the entire claimed debt is addressed, with the tribunal applying precedent to hold that where due publication of claims occurred and no creditors other than the applicant filed claims, the appellate forum may exercise jurisdiction to adjudicate and settle the dispute notwithstanding the expectation that the financial creditor seek formal withdrawal procedures; consequence: the appeal is disposed of and the impugned admission order is set aside.
Challenge to admission of an insolvency petition founded on a settlement following payment of the entire claimed debt is addressed, with the tribunal applying precedent to hold that where due publication of claims occurred and no creditors other than the applicant filed claims, the appellate forum may exercise jurisdiction to adjudicate and settle the dispute notwithstanding the expectation that the financial creditor seek formal withdrawal procedures; consequence: the appeal is disposed of and the impugned admission order is set aside.
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