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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Amends the Pre Pack regulations to redefine "fair value" as the estimated realizable value of the corporate debtor or its assets on the insolvency commencement date, computed after marketing and including tangible, intangible assets and underlying synergies. Requires appointment of two sets of registered valuers, each set comprising one valuer per asset class with a coordinating valuer. Prescribes a process: valuers to explain methodology to the committee, conduct physical verification, submit asset level fair and liquidation values to coordinating valuers, which compute set fair values considering synergies; the fair value of the corporate debtor is the average of the two coordinating valuer estimates and liquidation value is the asset class averages. Valuation reports must follow Board notified formats.
Amends the Pre Pack regulations to redefine "fair value" as the estimated realizable value of the corporate debtor or its assets on the insolvency commencement date, computed after marketing and including tangible, intangible assets and underlying synergies. Requires appointment of two sets of registered valuers, each set comprising one valuer per asset class with a coordinating valuer. Prescribes a process: valuers to explain methodology to the committee, conduct physical verification, submit asset level fair and liquidation values to coordinating valuers, which compute set fair values considering synergies; the fair value of the corporate debtor is the average of the two coordinating valuer estimates and liquidation value is the asset class averages. Valuation reports must follow Board notified formats.
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