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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Written acknowledgment of a subsisting debt before expiry of limitation can extend time under Section 18 of the Limitation Act, and such acknowledgment by the principal borrower may bind a personal guarantor because of co-extensive liability. A communication marked "without prejudice" does not lose evidentiary value if, read as a whole, it clearly records repayment, restructuring, or continuation of settlement discussions and amounts to an unequivocal admission of liability. An irrevocable and unconditional personal guarantee cannot be unilaterally revoked by later notice, and a release plea fails where the alleged release document is not properly brought on record.
Written acknowledgment of a subsisting debt before expiry of limitation can extend time under Section 18 of the Limitation Act, and such acknowledgment by the principal borrower may bind a personal guarantor because of co-extensive liability. A communication marked "without prejudice" does not lose evidentiary value if, read as a whole, it clearly records repayment, restructuring, or continuation of settlement discussions and amounts to an unequivocal admission of liability. An irrevocable and unconditional personal guarantee cannot be unilaterally revoked by later notice, and a release plea fails where the alleged release document is not properly brought on record.
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