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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A liquidation auction for sale of a corporate debtor as a going concern was confined to the corporate debtor on an as is where is, as is what is, whatever there is and no recourse basis, and an alleged business plan could not enlarge the sale to include subsidiaries, joint ventures, associates or other third-party assets. The text notes that such assets were not shown to form part of the liquidation estate, and the prayers for restraint against alienation and for further extension or amendment of the payment schedule were rejected. Cancellation of the bid for non-payment was upheld, but the forfeiture of deposited sums remained unresolved because the Members differed on that limited issue.
A liquidation auction for sale of a corporate debtor as a going concern was confined to the corporate debtor on an as is where is, as is what is, whatever there is and no recourse basis, and an alleged business plan could not enlarge the sale to include subsidiaries, joint ventures, associates or other third-party assets. The text notes that such assets were not shown to form part of the liquidation estate, and the prayers for restraint against alienation and for further extension or amendment of the payment schedule were rejected. Cancellation of the bid for non-payment was upheld, but the forfeiture of deposited sums remained unresolved because the Members differed on that limited issue.
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