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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NCLAT upheld rejection of appellant's belated claim for interest payments in liquidation proceedings. Appellant failed to file claims within prescribed timeline and later attempted to add interest component after two years from supply date. Court found interest claim was an afterthought, not included in original documentation. Appellant's attempt to circumvent Section 42 of IBC by filing under Section 60(5) was rejected. Liquidator's actions in seeking NOC for settling sub-contractor claims were deemed appropriate within scope of duties. Key principles established: claims must be filed within timeline, interest claims must be part of original submission, and Liquidator's decisions are final if not challenged within 14 days under Section 42. Appeal dismissed with no grounds for interference with impugned order.
NCLAT upheld rejection of appellant's belated claim for interest payments in liquidation proceedings. Appellant failed to file claims within prescribed timeline and later attempted to add interest component after two years from supply date. Court found interest claim was an afterthought, not included in original documentation. Appellant's attempt to circumvent Section 42 of IBC by filing under Section 60(5) was rejected. Liquidator's actions in seeking NOC for settling sub-contractor claims were deemed appropriate within scope of duties. Key principles established: claims must be filed within timeline, interest claims must be part of original submission, and Liquidator's decisions are final if not challenged within 14 days under Section 42. Appeal dismissed with no grounds for interference with impugned order.
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