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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Non-compliance of conditions of the Approved Resolution Plan by the Successful Resolution Applicant (SRA) - The Appellate Tribunal found that as per the order dated January 13, 2023, by the Adjudicating Authority, all conditions precedent as required under the approved Resolution Plan were fulfilled by the SRA by May 20, 2022. This included the validation of the Air Operator Certificate, submission and approval of the business plan, slots allotment approval, international traffic rights clearance, and the demerger of ground handling business into AGSL. - The Tribunal acknowledged the extensions and exclusions granted by the Adjudicating Authority for fulfilling the conditions precedent and for the infusion of the first tranche of funds. - The Tribunal did not grant the appellants' request for the liquidation of the corporate debtor under Section 33(3) of the IBC.
Non-compliance of conditions of the Approved Resolution Plan by the Successful Resolution Applicant (SRA) - The Appellate Tribunal found that as per the order dated January 13, 2023, by the Adjudicating Authority, all conditions precedent as required under the approved Resolution Plan were fulfilled by the SRA by May 20, 2022. This included the validation of the Air Operator Certificate, submission and approval of the business plan, slots allotment approval, international traffic rights clearance, and the demerger of ground handling business into AGSL. - The Tribunal acknowledged the extensions and exclusions granted by the Adjudicating Authority for fulfilling the conditions precedent and for the infusion of the first tranche of funds. - The Tribunal did not grant the appellants' request for the liquidation of the corporate debtor under Section 33(3) of the IBC.
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