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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The NCLAT upheld approval of the resolution plan, applying limited judicial review and the CoC's commercial wisdom because no breach of Section 30(2) or material procedural irregularity was shown. Objections on CIRP costs failed since the plan treated unpaid costs as payable at actuals and, in any event, the issue had become academic after implementation. The EPF treatment was sustained because the plan set aside funds from secured creditors' share for a contingent statutory liability, causing no prejudice to the dissenting creditor. The extension of the e-voting window, clarificatory communications, and rejection of a Swiss Challenge were also held permissible, and the appeals were dismissed.
The NCLAT upheld approval of the resolution plan, applying limited judicial review and the CoC's commercial wisdom because no breach of Section 30(2) or material procedural irregularity was shown. Objections on CIRP costs failed since the plan treated unpaid costs as payable at actuals and, in any event, the issue had become academic after implementation. The EPF treatment was sustained because the plan set aside funds from secured creditors' share for a contingent statutory liability, causing no prejudice to the dissenting creditor. The extension of the e-voting window, clarificatory communications, and rejection of a Swiss Challenge were also held permissible, and the appeals were dismissed.
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