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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Statutory trust rights under the NABARD Act and Rule 10 of the FSP Rules require the administrator to segregate third party receivables; filing a claim in Form C does not relinquish statutory entitlements, and providing transaction details preserves those rights. The adjudicating authority erred by treating the claimant's CoC membership and the resolution plan as extinguishing the statutory claim; the approved distribution mechanism already carved out amounts for the statutory claimant and mandates payment if the application succeeds. The appellate forum allowed the application, set aside the rejection, and ordered payment from the amount set apart with adjustment for sums previously paid.
Statutory trust rights under the NABARD Act and Rule 10 of the FSP Rules require the administrator to segregate third party receivables; filing a claim in Form C does not relinquish statutory entitlements, and providing transaction details preserves those rights. The adjudicating authority erred by treating the claimant's CoC membership and the resolution plan as extinguishing the statutory claim; the approved distribution mechanism already carved out amounts for the statutory claimant and mandates payment if the application succeeds. The appellate forum allowed the application, set aside the rejection, and ordered payment from the amount set apart with adjustment for sums previously paid.
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