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 period of limitation for filing a petition u/s 34 of the Arbitration Act commenced from 1st July 2022, excluding 30th June 2022 when the award was received. The three-month limitation period expired on 30th September 2022, a day before the pooja vacation commenced on 1st October 2022. The appellants were not entitled to the benefit of Section 4 of the Limitation Act as the prescribed period ended on 30th September 2022. The maximum 30-day extension u/s 34(3) expired on 30th October 2022, but the petition was filed on 31st October 2022. The High Court rightly held that the petition was not filed within the specified period u/s 34(3). The appeal was dismissed.
The period of limitation for filing a petition u/s 34 of the Arbitration Act commenced from 1st July 2022, excluding 30th June 2022 when the award was received. The three-month limitation period expired on 30th September 2022, a day before the pooja vacation commenced on 1st October 2022. The appellants were not entitled to the benefit of Section 4 of the Limitation Act as the prescribed period ended on 30th September 2022. The maximum 30-day extension u/s 34(3) expired on 30th October 2022, but the petition was filed on 31st October 2022. The High Court rightly held that the petition was not filed within the specified period u/s 34(3). The appeal was dismissed.
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