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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Natural justice was not violated in summary insolvency proceedings because the personal guarantor had opportunity to participate and provide explanations to the resolution professional, whose report was considered by the Adjudicating Authority; appeal dismissed on that ground. Pre existing commercial disputes do not bar admission of a petition under the insolvency code in Part III proceedings, and a later filed suit was immaterial. Insufficient stamping of the guarantee was held immaterial in summary IBC adjudication. The debtor's execution of the guarantee, disbursement, recall and demand notices established debt and default; the Adjudicating Authority's admission order is sustained and the appeal is dismissed.
Natural justice was not violated in summary insolvency proceedings because the personal guarantor had opportunity to participate and provide explanations to the resolution professional, whose report was considered by the Adjudicating Authority; appeal dismissed on that ground. Pre existing commercial disputes do not bar admission of a petition under the insolvency code in Part III proceedings, and a later filed suit was immaterial. Insufficient stamping of the guarantee was held immaterial in summary IBC adjudication. The debtor's execution of the guarantee, disbursement, recall and demand notices established debt and default; the Adjudicating Authority's admission order is sustained and the appeal is dismissed.
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