Natural justice in insolvency-professional discipline requires disclosed material; notices based on extraneous material and ignored defences are vitia...
Development rights transfers treated as immovable property, while construction abatement applies and repeated non-payment permits extended service-tax...
Income Disclosure Scheme immunity and search-material requirements barred further share-transaction additions in unabated assessments under section 15...
TNMM comparability must remain functionally robust: several software service comparables were excluded for lack of functional similarity, aggregate related-party transaction filtering was required for all selected comparables, and certain companies were restored for fresh FAR analysis or year-end data review. Working capital adjustment was restored because comparable margins must be adjusted for material profit-affecting differences; risk adjustment was refused for lack of demonstrated quantification, and delayed receivables were to be recomputed after giving effect to the final working capital adjustment. The mark-up on reimbursements was deleted for lack of factual and legal basis, interest income on the loan was remanded for fresh real-income examination, prepaid tax credit on amalgamation was to be verified and granted where corresponding income was offered, and penalty initiation was held premature.
TNMM comparability must remain functionally robust: several software service comparables were excluded for lack of functional similarity, aggregate related-party transaction filtering was required for all selected comparables, and certain companies were restored for fresh FAR analysis or year-end data review. Working capital adjustment was restored because comparable margins must be adjusted for material profit-affecting differences; risk adjustment was refused for lack of demonstrated quantification, and delayed receivables were to be recomputed after giving effect to the final working capital adjustment. The mark-up on reimbursements was deleted for lack of factual and legal basis, interest income on the loan was remanded for fresh real-income examination, prepaid tax credit on amalgamation was to be verified and granted where corresponding income was offered, and penalty initiation was held premature.
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