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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Interim relief seeking return of re quantified proceeds was refused because an interlocutory order cannot grant final relief and releasing the funds would risk dissipation that could render the respondent's cross appeal infructuous; the reduced quantification did not map to identifiable discrete assets, creating prima facie irreparable prejudice, so the interim application was dismissed while preserving substantive rights in the main appeal. To avoid multiplicity and balance equities, all appeals arising from the adjudicatory order are to be consolidated and heard expeditiously with prescribed pleading timelines and case management steps.
Interim relief seeking return of re quantified proceeds was refused because an interlocutory order cannot grant final relief and releasing the funds would risk dissipation that could render the respondent's cross appeal infructuous; the reduced quantification did not map to identifiable discrete assets, creating prima facie irreparable prejudice, so the interim application was dismissed while preserving substantive rights in the main appeal. To avoid multiplicity and balance equities, all appeals arising from the adjudicatory order are to be consolidated and heard expeditiously with prescribed pleading timelines and case management steps.
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