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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Moratorium under Section 14(1) prevents initiation or continuation of statutory assessment proceedings during CIRP, and assessments completed in the moratorium cannot form admissible CIRP claims; claims founded on such assessments are unenforceable. Claims filed after Committee of Creditors approval of a resolution plan cannot be entertained as time-barred because allowing them would reopen the resolution process. The Resolution Professional did not breach disclosure obligations where EPFO proceedings were not notified within the claim period and were absent from the suspended management's litigation list. Consequent adverse findings against the RP are expunged and the EPFO claim admission set aside.
Moratorium under Section 14(1) prevents initiation or continuation of statutory assessment proceedings during CIRP, and assessments completed in the moratorium cannot form admissible CIRP claims; claims founded on such assessments are unenforceable. Claims filed after Committee of Creditors approval of a resolution plan cannot be entertained as time-barred because allowing them would reopen the resolution process. The Resolution Professional did not breach disclosure obligations where EPFO proceedings were not notified within the claim period and were absent from the suspended management's litigation list. Consequent adverse findings against the RP are expunged and the EPFO claim admission set aside.
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