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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Payments of Rs. 19,66,698.77 made to a related party director within the two year look back period were treated as preferential transactions because the payments reduced the corporate debtor's liability to the related party and could not be excluded by tracing the source of funds. The tribunal held that Regulation 35A timelines are directory, not mandatory, and principles of natural justice were not breached where the adjudicating authority considered the appellant's written objections on merits despite an earlier ex parte notation. The liquidator's investigative power during liquidation to challenge preferential or undervalued transactions validated the challenge; appeals were dismissed.
Payments of Rs. 19,66,698.77 made to a related party director within the two year look back period were treated as preferential transactions because the payments reduced the corporate debtor's liability to the related party and could not be excluded by tracing the source of funds. The tribunal held that Regulation 35A timelines are directory, not mandatory, and principles of natural justice were not breached where the adjudicating authority considered the appellant's written objections on merits despite an earlier ex parte notation. The liquidator's investigative power during liquidation to challenge preferential or undervalued transactions validated the challenge; appeals were dismissed.
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