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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An appellant seeking repayment of a deposit must prove that the respondent company actually received the amount as its deposit; where the receipt and bank details showed credit to another entity treated as a separate legal person, the claim against the company was not maintainable on that basis. Once the company entered corporate insolvency resolution process, the moratorium barred continuation of pending proceedings and the insolvency framework became the only route for recovery through submission of a claim in the insolvency process. The appeal was therefore treated as infructuous, without prejudice to pursuit of the insolvency remedy.
An appellant seeking repayment of a deposit must prove that the respondent company actually received the amount as its deposit; where the receipt and bank details showed credit to another entity treated as a separate legal person, the claim against the company was not maintainable on that basis. Once the company entered corporate insolvency resolution process, the moratorium barred continuation of pending proceedings and the insolvency framework became the only route for recovery through submission of a claim in the insolvency process. The appeal was therefore treated as infructuous, without prejudice to pursuit of the insolvency remedy.
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