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 consent decree u/s 50C granted absolute ownership rights to Smt. Manju Agarwal over the 1314 sq.ft. office premises, allowing her to use, enjoy, and deal with it without objection. The property was sold by Nav Technology Pvt. Ltd., represented by Ms. Anmol Agarwal, without authority from other directors. The executing court cannot direct a person other than the vendor to bear tax liability arising from the transaction, as it would violate Income Tax Act provisions. While the judgment-debtors disregarded the decree's intention, the court cannot ask Smt. Manju Agarwal to shoulder tax responsibility at this stage. Further evidence is required regarding surrender or surrender value of the VIP Road property. As some decree obligations have been complied with, the other prayers cannot be allowed without specific details.
The consent decree u/s 50C granted absolute ownership rights to Smt. Manju Agarwal over the 1314 sq.ft. office premises, allowing her to use, enjoy, and deal with it without objection. The property was sold by Nav Technology Pvt. Ltd., represented by Ms. Anmol Agarwal, without authority from other directors. The executing court cannot direct a person other than the vendor to bear tax liability arising from the transaction, as it would violate Income Tax Act provisions. While the judgment-debtors disregarded the decree's intention, the court cannot ask Smt. Manju Agarwal to shoulder tax responsibility at this stage. Further evidence is required regarding surrender or surrender value of the VIP Road property. As some decree obligations have been complied with, the other prayers cannot be allowed without specific details.
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