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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Clarifications to a resolution plan that only address timing and operational aspects-such as confirmation that earmarked margin money will be returned to creditors and assurance of temporary replacement margin to banks-do not constitute enhancement or modification of the plan; similarly, explaining that a stated figure is the discounted present value of deferred payments does not alter the commercial offer. The resolution professional who acted on explicit Committee of Creditors instructions did not commit material irregularity. Concurrent factual findings that no modification or material irregularity occurred bar judicial substitution of the CoC's commercial wisdom, and the appeals were dismissed accordingly.
Clarifications to a resolution plan that only address timing and operational aspects-such as confirmation that earmarked margin money will be returned to creditors and assurance of temporary replacement margin to banks-do not constitute enhancement or modification of the plan; similarly, explaining that a stated figure is the discounted present value of deferred payments does not alter the commercial offer. The resolution professional who acted on explicit Committee of Creditors instructions did not commit material irregularity. Concurrent factual findings that no modification or material irregularity occurred bar judicial substitution of the CoC's commercial wisdom, and the appeals were dismissed accordingly.
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