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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Oppression and Mismanagement - Issue of Right Shares - subsequent Rights Issue during the pendency of 1st Rights Issue - gross under-subscription of the rights issue - `non-participation’ in the `Legitimate 1st Rights Issue’ - In terms of the ingredients of Section 62 of the Companies Act, 2013, the Directors have to offer further Shares issued, to the Shareholders who are on the Register of Companies and not to anyone else, and in fact, the Offer must be in the same proportion to all the Shareholders. It is to be remembered that there shall be no discrimination among them. - AT
Oppression and Mismanagement - Issue of Right Shares - subsequent Rights Issue during the pendency of 1st Rights Issue - gross under-subscription of the rights issue - `non-participation’ in the `Legitimate 1st Rights Issue’ - In terms of the ingredients of Section 62 of the Companies Act, 2013, the Directors have to offer further Shares issued, to the Shareholders who are on the Register of Companies and not to anyone else, and in fact, the Offer must be in the same proportion to all the Shareholders. It is to be remembered that there shall be no discrimination among them. - AT
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