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 of a corporate guarantee on 12.02.2020 triggered a fresh cause of action, starting the threeyear limitation period, and balance sheet entries in 202122 and 202324 constituted acknowledgements under Section 18 of the Limitation Act, thereby extending limitation and rendering the petition filed on 14.04.2025 timely. The insolvency petition's Form1 contained pleaded particulars of debt and date of default; the Adjudicating Authority correctly treated the application as complete and admitted it. Realisations recorded in liquidation and a related corporate guarantor's resolution process were public and did not amount to suppression. The appellate tribunal dismissed the challenge to admission.
Invocation of a corporate guarantee on 12.02.2020 triggered a fresh cause of action, starting the threeyear limitation period, and balance sheet entries in 202122 and 202324 constituted acknowledgements under Section 18 of the Limitation Act, thereby extending limitation and rendering the petition filed on 14.04.2025 timely. The insolvency petition's Form1 contained pleaded particulars of debt and date of default; the Adjudicating Authority correctly treated the application as complete and admitted it. Realisations recorded in liquidation and a related corporate guarantor's resolution process were public and did not amount to suppression. The appellate tribunal dismissed the challenge to admission.
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