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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Information memorandum disclosed the existence of corporation dues and advised prospective resolution applicants to verify such claims; consequence: non-filing despite notice did not negate the disclosed claim. Adjudicating Authority exercised discretion to admit a belatedly filed claim after noting the information memorandum; consequence: admission of the claim was upheld and cannot be interfered with on appeal. Resolution Professional and successful resolution applicant are entitled to submit an addendum to the resolution plan following admission of the claim; consequence: they must take consequential actions to incorporate the admitted claim. Protective effect of insolvency process does not override statutory dues; consequence: statutory claims remain enforceable.
Information memorandum disclosed the existence of corporation dues and advised prospective resolution applicants to verify such claims; consequence: non-filing despite notice did not negate the disclosed claim. Adjudicating Authority exercised discretion to admit a belatedly filed claim after noting the information memorandum; consequence: admission of the claim was upheld and cannot be interfered with on appeal. Resolution Professional and successful resolution applicant are entitled to submit an addendum to the resolution plan following admission of the claim; consequence: they must take consequential actions to incorporate the admitted claim. Protective effect of insolvency process does not override statutory dues; consequence: statutory claims remain enforceable.
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