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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Existence of financial debt was affirmed where original loan was sanctioned by a bank and subsequently assigned to an ARC, reflected in the corporate debtor's audited accounts and supporting security documents, so debt and default were established for Section 7 admission. The application was within limitation as per audited acknowledgements. Procedural defects-authorization, inadequate stamping, non-service on Information Utility-were treated as curable when cured during proceedings and did not defeat admission. Electronic records and bank statements were admissible at admission stage without a Section 65B certificate, and allegations of mala fides were unsustainable on the record.
Existence of financial debt was affirmed where original loan was sanctioned by a bank and subsequently assigned to an ARC, reflected in the corporate debtor's audited accounts and supporting security documents, so debt and default were established for Section 7 admission. The application was within limitation as per audited acknowledgements. Procedural defects-authorization, inadequate stamping, non-service on Information Utility-were treated as curable when cured during proceedings and did not defeat admission. Electronic records and bank statements were admissible at admission stage without a Section 65B certificate, and allegations of mala fides were unsustainable on the record.
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