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 AT held that stock split is a price sensitive information as it is likely to impact the price of securities. The UPSI period commenced from March 20, 2017 when the discussion specifically included analysis of stock split for IAL. However, the appellants cannot be considered insiders merely because they subscribed to IAL's pre-IPO preferential allotment. There was no evidence that appellants had access to or possessed UPSI when trading in IAL's scrip. Hence, the appeal was allowed.
The AT held that stock split is a price sensitive information as it is likely to impact the price of securities. The UPSI period commenced from March 20, 2017 when the discussion specifically included analysis of stock split for IAL. However, the appellants cannot be considered insiders merely because they subscribed to IAL's pre-IPO preferential allotment. There was no evidence that appellants had access to or possessed UPSI when trading in IAL's scrip. Hence, the appeal was allowed.
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