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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Invocation by legal notice was held sufficient to sustain a guarantee invocation application, and the Adjudicating Authority's rejection for lack of a demand notice was quashed. The interim moratorium principle was applied to commence from filing of the guarantee invocation application, so defects alleged by the auction purchaser did not prevent moratorium. Documentary shortfalls (income-tax returns) were found not to render the petition defective, and the petition was reinstated. The Adjudicating Authority was directed to exercise jurisdiction and pass fresh orders under the revival provision without delay.
Invocation by legal notice was held sufficient to sustain a guarantee invocation application, and the Adjudicating Authority's rejection for lack of a demand notice was quashed. The interim moratorium principle was applied to commence from filing of the guarantee invocation application, so defects alleged by the auction purchaser did not prevent moratorium. Documentary shortfalls (income-tax returns) were found not to render the petition defective, and the petition was reinstated. The Adjudicating Authority was directed to exercise jurisdiction and pass fresh orders under the revival provision without delay.
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