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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Liquidation process costs - expenses for preventing any damage due to possible collision between the vessels - The liquidator took action after receiving consent from the Appellant for preservation and protection of vessel Tag 22 during 3rd – 5th October, 2019 much after the Appellant had invoked Admiralty Jurisdiction of Hon’ble Bombay High Court to realise its security charge in vessel Tag 22. Subsequently, when invoice received from K.E. Salvage Company was sent for payment to the Appellant by the liquidator, the Appellant went for litigation against making payment of said invoice. - payment to be made by the Appellant - AT
Liquidation process costs - expenses for preventing any damage due to possible collision between the vessels - The liquidator took action after receiving consent from the Appellant for preservation and protection of vessel Tag 22 during 3rd – 5th October, 2019 much after the Appellant had invoked Admiralty Jurisdiction of Hon’ble Bombay High Court to realise its security charge in vessel Tag 22. Subsequently, when invoice received from K.E. Salvage Company was sent for payment to the Appellant by the liquidator, the Appellant went for litigation against making payment of said invoice. - payment to be made by the Appellant - AT
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