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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Disciplinary scrutiny of an interim resolution professional focused on alleged misrepresentation, concealment and reconstitution of the committee of creditors without approval. The tribunal found the IRP was given specific directions and an opportunity to explain discrepancies but did not avail the chances; therefore observations characterising the IRP's conduct as prejudicial to the corporate insolvency resolution process were supported by the record. The request to expunge adverse observations for breach of natural justice was rejected and the appeals were dismissed.
Disciplinary scrutiny of an interim resolution professional focused on alleged misrepresentation, concealment and reconstitution of the committee of creditors without approval. The tribunal found the IRP was given specific directions and an opportunity to explain discrepancies but did not avail the chances; therefore observations characterising the IRP's conduct as prejudicial to the corporate insolvency resolution process were supported by the record. The request to expunge adverse observations for breach of natural justice was rejected and the appeals were dismissed.
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