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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Persons who acquired or sold a secured asset during an operative moratorium were entitled to be heard because their substantive civil rights were exposed to adjudicatory scrutiny; the tribunal applied the principle that parties whose rights may be affected by ongoing proceedings are necessary and proper parties and may be impleaded to prevent collateral damage. On that basis both impleader applications were allowed, the applicants were directed to be impleaded as respondents, and the appellant was ordered to amend the memorandum of parties, serve appeal papers on them, and comply with specified timelines for objections and rejoinders.
Persons who acquired or sold a secured asset during an operative moratorium were entitled to be heard because their substantive civil rights were exposed to adjudicatory scrutiny; the tribunal applied the principle that parties whose rights may be affected by ongoing proceedings are necessary and proper parties and may be impleaded to prevent collateral damage. On that basis both impleader applications were allowed, the applicants were directed to be impleaded as respondents, and the appellant was ordered to amend the memorandum of parties, serve appeal papers on them, and comply with specified timelines for objections and rejoinders.
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