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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Whether spectrum licensing rights fall within the corporate insolvency estate under the IBC: the article states that spectrum is a public resource held in trust and that Spectrum Trading Guidelines reserve comprehensive supervisory and corrective control to the State (including annulment of trades and recovery of dues), showing trading is a conditional privilege rather than a transferred proprietary title. IBC applies only to assets owned by the corporate debtor as recorded; mere recognition of licensing rights in financial statements does not create ownership. Consequently, telecom statutes and regulatory regime occupy the legal province over spectrum and spectrum licensing rights cannot be subjected to IBC proceedings.
Whether spectrum licensing rights fall within the corporate insolvency estate under the IBC: the article states that spectrum is a public resource held in trust and that Spectrum Trading Guidelines reserve comprehensive supervisory and corrective control to the State (including annulment of trades and recovery of dues), showing trading is a conditional privilege rather than a transferred proprietary title. IBC applies only to assets owned by the corporate debtor as recorded; mere recognition of licensing rights in financial statements does not create ownership. Consequently, telecom statutes and regulatory regime occupy the legal province over spectrum and spectrum licensing rights cannot be subjected to IBC proceedings.
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