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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Section 5 of the Stamp Act applies where a single instrument embodies several distinct matters so that each is separately chargeable; the court found that the NCLT sanction order cannot be dissected into separate instruments for stamp duty by examining underlying transactions. An order originating outside the State is not chargeable under Section 19 merely because it is referenced in a local NCLT order; stamp authorities in the receiving State lack jurisdiction absent receipt or execution within that State. The impugned assessment segregating mergers into distinct transactions was erroneous; the writ is allowed and the assessment orders are quashed and set aside.
Section 5 of the Stamp Act applies where a single instrument embodies several distinct matters so that each is separately chargeable; the court found that the NCLT sanction order cannot be dissected into separate instruments for stamp duty by examining underlying transactions. An order originating outside the State is not chargeable under Section 19 merely because it is referenced in a local NCLT order; stamp authorities in the receiving State lack jurisdiction absent receipt or execution within that State. The impugned assessment segregating mergers into distinct transactions was erroneous; the writ is allowed and the assessment orders are quashed and set aside.
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