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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Insolvency and BankruptcyNovember 3, 2022Case LawsAT
Condonation of delay of 13 days in filing the Appeals - The present is a case where Appellant cannot be blamed for not applying the certified copy of the Order dated 08th June, 2022 since according to the Appellant, the Order was not pronounced nor it was uploaded although Appellant was present in the Hearing and his Learned Counsels participated in the Hearing raising objection regarding the maintainability of the Application. - The present is a case where the Appeal cannot be thrown out on the ground of limitation - AT
Condonation of delay of 13 days in filing the Appeals - The present is a case where Appellant cannot be blamed for not applying the certified copy of the Order dated 08th June, 2022 since according to the Appellant, the Order was not pronounced nor it was uploaded although Appellant was present in the Hearing and his Learned Counsels participated in the Hearing raising objection regarding the maintainability of the Application. - The present is a case where the Appeal cannot be thrown out on the ground of limitation - AT
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