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...
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Regulation 20(1) requires a competing acquirer to make its public announcement within 15 working days of the first acquirer's detailed public statement. The period cannot be reckoned from dispatch or advertisement of the first acquirer's letter of offer, because that would disturb the uniform statutory timetable for competing offers and prejudice a compliant first offeror. A competing offer made after that period could not be entertained. Regulation 11 permits exemption only from the obligation to make an open offer; it does not waive procedural requirements or competing-offer timelines. Once the first open offer had concluded, the exemption request was untenable, without preventing a fresh takeover bid under the SAST Regulations.
Regulation 20(1) requires a competing acquirer to make its public announcement within 15 working days of the first acquirer's detailed public statement. The period cannot be reckoned from dispatch or advertisement of the first acquirer's letter of offer, because that would disturb the uniform statutory timetable for competing offers and prejudice a compliant first offeror. A competing offer made after that period could not be entertained. Regulation 11 permits exemption only from the obligation to make an open offer; it does not waive procedural requirements or competing-offer timelines. Once the first open offer had concluded, the exemption request was untenable, without preventing a fresh takeover bid under the SAST Regulations.
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