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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Waiver under Section 244 for a company limited by guarantee was considered on the basis of prima facie oppression and mismanagement, exceptional circumstances, and alleged violation of the Articles of Association. The Appellate Tribunal accepted that at the waiver stage a detailed merits review was unnecessary and that concise reasons were sufficient if relevant factors were considered. It found that the order had addressed the club's affairs, the alleged illegal termination and suspension of a member during pending proceedings, the convening of the EOGM, and broader mismanagement allegations. The challenge was treated as affecting members' rights and club governance, and the withdrawal of 49 members did not defeat waiver at that stage.
Waiver under Section 244 for a company limited by guarantee was considered on the basis of prima facie oppression and mismanagement, exceptional circumstances, and alleged violation of the Articles of Association. The Appellate Tribunal accepted that at the waiver stage a detailed merits review was unnecessary and that concise reasons were sufficient if relevant factors were considered. It found that the order had addressed the club's affairs, the alleged illegal termination and suspension of a member during pending proceedings, the convening of the EOGM, and broader mismanagement allegations. The challenge was treated as affecting members' rights and club governance, and the withdrawal of 49 members did not defeat waiver at that stage.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4826 
Join Channel 
