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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Provident fund claims in CIRP must rest on crystallised statutory dues; an internal communication or tentative computation cannot by itself establish an admissible claim. The Appellate Tribunal held that, where the provident fund liability had not been assessed and crystallised at the relevant time, the claim could not be sustained on the basis of a provisional document alone. The rejection of the application was therefore upheld and the appeal dismissed.
Provident fund claims in CIRP must rest on crystallised statutory dues; an internal communication or tentative computation cannot by itself establish an admissible claim. The Appellate Tribunal held that, where the provident fund liability had not been assessed and crystallised at the relevant time, the claim could not be sustained on the basis of a provisional document alone. The rejection of the application was therefore upheld and the appeal dismissed.
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