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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Provisional attachment of properties held by company officials was sustained where they were found to have actively assisted directors in promoting unlawful preference-share schemes, mobilising public investments and diverting proceeds of the scheduled offence. Recorded statements and charge-sheet material linked the officials to the acquisition of properties in their names. Their claim that the properties were purchased solely from salary and incentives was rejected because the attached value was substantially lower than amounts received from the company. The attachment remains subject to the final outcome of the criminal proceedings.
Provisional attachment of properties held by company officials was sustained where they were found to have actively assisted directors in promoting unlawful preference-share schemes, mobilising public investments and diverting proceeds of the scheduled offence. Recorded statements and charge-sheet material linked the officials to the acquisition of properties in their names. Their claim that the properties were purchased solely from salary and incentives was rejected because the attached value was substantially lower than amounts received from the company. The attachment remains subject to the final outcome of the criminal proceedings.
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