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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Unauthorised dispositions during moratorium are void and any money received affecting the liquidation estate must be restored; the Liquidator alone held authority to deal with estate assets once CIRP commenced and liquidation commenced, so the Agreement to Sell dated 13.12.2019 and receipt of funds by related parties were examined for restitution. Belated criminal allegations of forgery and post order complaints do not defeat statutory restorative relief; a subsequent accounting entry claiming an unsecured loan, without supporting documents, cannot override contemporaneous facts linking payment to the sale agreement. The Adjudicating Authority's order directing deposit of the sum into the liquidation estate was upheld.
Unauthorised dispositions during moratorium are void and any money received affecting the liquidation estate must be restored; the Liquidator alone held authority to deal with estate assets once CIRP commenced and liquidation commenced, so the Agreement to Sell dated 13.12.2019 and receipt of funds by related parties were examined for restitution. Belated criminal allegations of forgery and post order complaints do not defeat statutory restorative relief; a subsequent accounting entry claiming an unsecured loan, without supporting documents, cannot override contemporaneous facts linking payment to the sale agreement. The Adjudicating Authority's order directing deposit of the sum into the liquidation estate was upheld.
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