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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Acknowledgements and out of court restructuring proposals constituted valid acknowledgements under the Limitation Act, extending limitation and rendering the insolvency petition timely; this conclusion was upheld. Substituted service by publication, the debtor counsel's subsequent appearance, and multiple adjournments afforded before the ex parte order established that principles of natural justice were respected; no breach was found. Documentary evidence of disbursement, the debtor's repeated restructuring requests and one-time settlement offers supported findings of debt and default, justifying admission of the insolvency petition and appointment of an interim resolution professional. The appeal was dismissed and the admission upheld.
Acknowledgements and out of court restructuring proposals constituted valid acknowledgements under the Limitation Act, extending limitation and rendering the insolvency petition timely; this conclusion was upheld. Substituted service by publication, the debtor counsel's subsequent appearance, and multiple adjournments afforded before the ex parte order established that principles of natural justice were respected; no breach was found. Documentary evidence of disbursement, the debtor's repeated restructuring requests and one-time settlement offers supported findings of debt and default, justifying admission of the insolvency petition and appointment of an interim resolution professional. The appeal was dismissed and the admission upheld.
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