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 - Deletion of names of Respondent No. 4 to 8 and 13 from the array of the Respondents - Section 241, 242 and 243 of Companies Act - The Tribunal allowed the deletion of the respondents but imposed a token amount of Rs. 5,00,000/- as compensation for the loss suffered by them due to the order of stay. The Appellant contested this decision, arguing that the imposition of cost was unwarranted since the respondents were rightfully impleaded initially. However, the Appellate Tribunal upheld its decision, stating that the respondents were unnecessarily dragged into the litigation, causing them business losses and reputational harm. The appeal was dismissed, affirming the Tribunal's decision.
Oppression and Mismanagement - Deletion of names of Respondent No. 4 to 8 and 13 from the array of the Respondents - Section 241, 242 and 243 of Companies Act - The Tribunal allowed the deletion of the respondents but imposed a token amount of Rs. 5,00,000/- as compensation for the loss suffered by them due to the order of stay. The Appellant contested this decision, arguing that the imposition of cost was unwarranted since the respondents were rightfully impleaded initially. However, the Appellate Tribunal upheld its decision, stating that the respondents were unnecessarily dragged into the litigation, causing them business losses and reputational harm. The appeal was dismissed, affirming the Tribunal's decision.
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