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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Seeking restoration of name of company in the Register of Companies - Company had not filed their `Balance Sheet(s)’ and Annual Return(s)’ for more than 12 years - the `right to seek restoration’ of the name of the `company’ (to be entered in the `Register of Companies’) is not wiped out, as long as `twenty years’ have not lapsed, etc. - it is just and proper to restore the Appellant / Company’s name and that the failure / negligence / omissions on the part of the `Appellant’/`Company’ in not filing the `Statutory Annual Returns’ and `Financial Statements’ in time, can be saddled with a levy of costs, to prevent an aberration of justice and to promote substantial cause of justice. - AT
Seeking restoration of name of company in the Register of Companies - Company had not filed their `Balance Sheet(s)’ and Annual Return(s)’ for more than 12 years - the `right to seek restoration’ of the name of the `company’ (to be entered in the `Register of Companies’) is not wiped out, as long as `twenty years’ have not lapsed, etc. - it is just and proper to restore the Appellant / Company’s name and that the failure / negligence / omissions on the part of the `Appellant’/`Company’ in not filing the `Statutory Annual Returns’ and `Financial Statements’ in time, can be saddled with a levy of costs, to prevent an aberration of justice and to promote substantial cause of justice. - AT
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