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 held that appellants could not later complain of lack of notice or hearing where they were represented by counsel when the interlocutory applications were taken up, since knowledge of the proceedings and an opportunity to object were attributable to them. It further upheld exclusion of 208 days from the personal guarantor insolvency resolution process, ruling that the period spent in earlier appeals could be excluded to give effect to prior appellate directions and that the statutory time limit operates as a moratorium-related provision, not as a bar on exclusion of time for effective continuation of the process. The exclusion was treated as a procedural measure and the appeals were dismissed.
The NCLAT held that appellants could not later complain of lack of notice or hearing where they were represented by counsel when the interlocutory applications were taken up, since knowledge of the proceedings and an opportunity to object were attributable to them. It further upheld exclusion of 208 days from the personal guarantor insolvency resolution process, ruling that the period spent in earlier appeals could be excluded to give effect to prior appellate directions and that the statutory time limit operates as a moratorium-related provision, not as a bar on exclusion of time for effective continuation of the process. The exclusion was treated as a procedural measure and the appeals were dismissed.
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