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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An unregistered assignment deed was treated as sufficient prima facie basis for substitution of the assignee in proceedings, because permitting the assignee to contest the matter was considered a collateral purpose distinct from determining the deed's validity or transfer effect. Relying on the principle that an unregistered document may be read for a collateral purpose, the Tribunal left all objections under Sections 17 and 49 of the Registration Act open for decision in the main company petition. The substitution of the assignee was therefore maintained, while the challenge to the assignment deed's admissibility, enforceability and legal effect was reserved for final adjudication.
An unregistered assignment deed was treated as sufficient prima facie basis for substitution of the assignee in proceedings, because permitting the assignee to contest the matter was considered a collateral purpose distinct from determining the deed's validity or transfer effect. Relying on the principle that an unregistered document may be read for a collateral purpose, the Tribunal left all objections under Sections 17 and 49 of the Registration Act open for decision in the main company petition. The substitution of the assignee was therefore maintained, while the challenge to the assignment deed's admissibility, enforceability and legal effect was reserved for final adjudication.
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