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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Rejection of prayer of Operational Creditor to initiate the CIRP against the Corporate Debtor - The Appellate tribunal (NCLAT) found no breach of the contract terms by the respondent as the initial agreed terms were for the appellant to pick up the goods from the respondent's location. It was determined that the appellant attempted to shift the terms in the appellate documents, which were not presented at the Adjudicating Authority. The tribunal concluded that there was a pre-existing dispute regarding the delivery and payment terms, substantiated by the evidence of email exchanges and the non-collection of goods. - The tribunal upheld the decision of the Adjudicating Authority
Rejection of prayer of Operational Creditor to initiate the CIRP against the Corporate Debtor - The Appellate tribunal (NCLAT) found no breach of the contract terms by the respondent as the initial agreed terms were for the appellant to pick up the goods from the respondent's location. It was determined that the appellant attempted to shift the terms in the appellate documents, which were not presented at the Adjudicating Authority. The tribunal concluded that there was a pre-existing dispute regarding the delivery and payment terms, substantiated by the evidence of email exchanges and the non-collection of goods. - The tribunal upheld the decision of the Adjudicating Authority
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