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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Entitlement to liquidator fees was determined by applying the time based bucket fee structure in the liquidation regulations: where effective realisation occurred after one year, fees must be computed at the third bucket rates, and amounts withdrawn in excess are refundable with applicable GST and interest. The Adjudicating Authority excluded certain recognised interruption periods but declined an additional 141 day exclusion for post medical resumption of auctions; on review the Tribunal found no error in that factual and regulatory application and affirmed the third bucket calculation and refund direction. Separate procedural relief: a 56 day delay in re filing the appeal was condoned.
Entitlement to liquidator fees was determined by applying the time based bucket fee structure in the liquidation regulations: where effective realisation occurred after one year, fees must be computed at the third bucket rates, and amounts withdrawn in excess are refundable with applicable GST and interest. The Adjudicating Authority excluded certain recognised interruption periods but declined an additional 141 day exclusion for post medical resumption of auctions; on review the Tribunal found no error in that factual and regulatory application and affirmed the third bucket calculation and refund direction. Separate procedural relief: a 56 day delay in re filing the appeal was condoned.
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