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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HC allowed appeal against trial court's decision invalidating a gift deed and granting permanent injunction. While trial court focused solely on fraud allegation without conclusively establishing it, HC found the gift deed valid based on intrinsic evidence showing donor's clear intention and explanation for the transfer. Though Clause II(6) of lease deed required written consent for property transfer, its violation would only affect lease renewal, not invalidate the transfer itself. Donor's explicit statement of love and affection for donee (daughter-in-law), coupled with confirmation by other family members, established deed's validity. Trial court's judgment declaring gift deed void and granting injunction was set aside, and original suit dismissed without costs.
HC allowed appeal against trial court's decision invalidating a gift deed and granting permanent injunction. While trial court focused solely on fraud allegation without conclusively establishing it, HC found the gift deed valid based on intrinsic evidence showing donor's clear intention and explanation for the transfer. Though Clause II(6) of lease deed required written consent for property transfer, its violation would only affect lease renewal, not invalidate the transfer itself. Donor's explicit statement of love and affection for donee (daughter-in-law), coupled with confirmation by other family members, established deed's validity. Trial court's judgment declaring gift deed void and granting injunction was set aside, and original suit dismissed without costs.
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