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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The note addresses threshold applicability in insolvency petitions, concluding the claimed default date fell outside the temporal provision and therefore the petition could not seek relief under that threshold; this legal point determined maintainability. It also affirms recoverability of contractual interest where invoices and purchase orders expressly provided for post due interest and the statement of account recorded invoice dates, numbers, due dates and interest, making the claimed sums evidentially supported. The article records that the appellate review found no illegality in the impugned order and dismissed the appeal for lack of merit.
The note addresses threshold applicability in insolvency petitions, concluding the claimed default date fell outside the temporal provision and therefore the petition could not seek relief under that threshold; this legal point determined maintainability. It also affirms recoverability of contractual interest where invoices and purchase orders expressly provided for post due interest and the statement of account recorded invoice dates, numbers, due dates and interest, making the claimed sums evidentially supported. The article records that the appellate review found no illegality in the impugned order and dismissed the appeal for lack of merit.
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