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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Adjudicatory authority rejected claimed interest as an inadmissible component of financial debt where interest at 24% p.a. compounded monthly was unsupported by bona fide documentation. Related-party advances lacked board resolutions, were not registered as a charge with RoC, and interest was not reflected in the corporate debtor's books; repayment terms were unset. The tribunal accepted these factual and accounting defects and upheld disallowance of the disputed interest, dismissing the appeal and affirming the liquidator's position.
Adjudicatory authority rejected claimed interest as an inadmissible component of financial debt where interest at 24% p.a. compounded monthly was unsupported by bona fide documentation. Related-party advances lacked board resolutions, were not registered as a charge with RoC, and interest was not reflected in the corporate debtor's books; repayment terms were unset. The tribunal accepted these factual and accounting defects and upheld disallowance of the disputed interest, dismissing the appeal and affirming the liquidator's position.
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