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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Initiation of CIRP - operational debt claimed by RCL was due and payable or not - While the initial operational debt was cleared, issues related to GST payments and credits were highlighted as unresolved. However, these were not part of the original claim under the CIRP application, hence could not be considered as grounds for insolvency under the IBC framework. - The Tribunal allowed the appeal, setting aside the order admitting the corporate debtor into CIRP. It acknowledged the full payment of the operational debt but noted the corporate debtor's responsibility concerning the GST issues, suggesting that the creditor might pursue other legal remedies for this part of the debt.
Initiation of CIRP - operational debt claimed by RCL was due and payable or not - While the initial operational debt was cleared, issues related to GST payments and credits were highlighted as unresolved. However, these were not part of the original claim under the CIRP application, hence could not be considered as grounds for insolvency under the IBC framework. - The Tribunal allowed the appeal, setting aside the order admitting the corporate debtor into CIRP. It acknowledged the full payment of the operational debt but noted the corporate debtor's responsibility concerning the GST issues, suggesting that the creditor might pursue other legal remedies for this part of the debt.
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