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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Application for extension of time u/s 29A(5) of the Arbitration and Conciliation Act, 1996 can be filed even after the expiry of the period for making the arbitral award. The court has the power to extend the time period for making the award, not the arbitral tribunal. If an award is pronounced during the pendency of an application for extension, the court must still decide the application and may invoke sub-sections (6) to (8) or the relevant provisos of Section 29A(4). While interpreting a statute, an interpretation producing an unreasonable result should be avoided if there is another acceptable, practical, and pragmatic construction.
Application for extension of time u/s 29A(5) of the Arbitration and Conciliation Act, 1996 can be filed even after the expiry of the period for making the arbitral award. The court has the power to extend the time period for making the award, not the arbitral tribunal. If an award is pronounced during the pendency of an application for extension, the court must still decide the application and may invoke sub-sections (6) to (8) or the relevant provisos of Section 29A(4). While interpreting a statute, an interpretation producing an unreasonable result should be avoided if there is another acceptable, practical, and pragmatic construction.
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