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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Share application money was treated as financial debt and the appellate tribunal applied res judicata to reject reopening issues already finally decided; consequence: the subsequent insolvency petition under Section 7 was properly admitted where the corporate debtor failed to refund amounts after prior proceedings. The tribunal found earlier assurances to refund were not genuine and, on merits, upheld admission of the petition and dismissed the appeal. Consequent orders directed refund of the interim deposit to the appellant, permitted the appellant to remit specified sums to the financial creditor, and allowed the resolution professional to continue CIRP excluding the specified interim period.
Share application money was treated as financial debt and the appellate tribunal applied res judicata to reject reopening issues already finally decided; consequence: the subsequent insolvency petition under Section 7 was properly admitted where the corporate debtor failed to refund amounts after prior proceedings. The tribunal found earlier assurances to refund were not genuine and, on merits, upheld admission of the petition and dismissed the appeal. Consequent orders directed refund of the interim deposit to the appellant, permitted the appellant to remit specified sums to the financial creditor, and allowed the resolution professional to continue CIRP excluding the specified interim period.
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