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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Interlocutory relief can be merged into and overtaken by a subsequent comprehensive supervisory order; where a final common order restructures management, orders a forensic audit and appoints an Independent Administrator under statutory management powers, earlier interim directions become part of that larger regime and an appeal against the interim step may be rendered infructuous. Maintainability objections had to be raised before the adjudicating authority; petitioner eligibility was satisfied by admitted shareholding above the statutory threshold. Any disputes over SPA clauses or receivables must now be addressed within the framework of the common order or upon the forensic audit report.
Interlocutory relief can be merged into and overtaken by a subsequent comprehensive supervisory order; where a final common order restructures management, orders a forensic audit and appoints an Independent Administrator under statutory management powers, earlier interim directions become part of that larger regime and an appeal against the interim step may be rendered infructuous. Maintainability objections had to be raised before the adjudicating authority; petitioner eligibility was satisfied by admitted shareholding above the statutory threshold. Any disputes over SPA clauses or receivables must now be addressed within the framework of the common order or upon the forensic audit report.
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