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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Finality of higher-court orders prevents a lower court from revisiting or altering the operative effect of an earlier superior-court relief so as to prejudice beneficiaries; the appellants' promotions implemented pursuant to the earlier order were protected and the appeal was allowed limitedly to safeguard their career progression. Persons not impleaded in earlier proceedings but asserting prejudice from those decisions are not without remedy: the Court reaffirmed precedents permitting limited review or fresh proceedings before competent tribunals and granted intervenors liberty to pursue appropriate fora to seek individual relief; connected applications were disposed accordingly.
Finality of higher-court orders prevents a lower court from revisiting or altering the operative effect of an earlier superior-court relief so as to prejudice beneficiaries; the appellants' promotions implemented pursuant to the earlier order were protected and the appeal was allowed limitedly to safeguard their career progression. Persons not impleaded in earlier proceedings but asserting prejudice from those decisions are not without remedy: the Court reaffirmed precedents permitting limited review or fresh proceedings before competent tribunals and granted intervenors liberty to pursue appropriate fora to seek individual relief; connected applications were disposed accordingly.
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