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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CIRP - waterfall mechanism - extinguishment of demand of the State Tax Authorities - The Patna High Court ruled in favor of the petitioner, holding that the tax demands for the assessment years 2020-21 and 2022-23 stood extinguished as they were not included in the resolution plan approved by the NCLT. The court emphasized the binding nature of the resolution plan on all stakeholders, including the State Government, and reiterated the principle that claims not lodged during the CIRP process cannot be enforced later.
CIRP - waterfall mechanism - extinguishment of demand of the State Tax Authorities - The Patna High Court ruled in favor of the petitioner, holding that the tax demands for the assessment years 2020-21 and 2022-23 stood extinguished as they were not included in the resolution plan approved by the NCLT. The court emphasized the binding nature of the resolution plan on all stakeholders, including the State Government, and reiterated the principle that claims not lodged during the CIRP process cannot be enforced later.
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