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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The High Court addressed the issue of the relevant date for adjudicating claims in a liquidation scenario. The Court held that claims should be adjudicated up to the date of the provisional liquidator's appointment, not the final winding-up date. The Bank of Baroda had dual claims, one as a secured creditor and one as a Debenture Trustee. The applicant's claim settlement assertions were found factually incorrect as the Bank was entitled to recover a specific amount. Orders upholding these claims were not challenged and finalized. The Court dismissed the application, finding no errors warranting review.
The High Court addressed the issue of the relevant date for adjudicating claims in a liquidation scenario. The Court held that claims should be adjudicated up to the date of the provisional liquidator's appointment, not the final winding-up date. The Bank of Baroda had dual claims, one as a secured creditor and one as a Debenture Trustee. The applicant's claim settlement assertions were found factually incorrect as the Bank was entitled to recover a specific amount. Orders upholding these claims were not challenged and finalized. The Court dismissed the application, finding no errors warranting review.
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