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 determined the petitioner was entitled to release of Rs.15.90 lakhs realized from share sales. The court found the petitioner genuinely placed shares for sale through Respondent No. 2, with fraud occurring at Respondent's end through Amit Jain and potentially Ashish Aggarwal Jain. No evidence implicated the petitioner in the fraudulent transaction. Despite inconsistencies in the petitioner's statements regarding share numbers, the court acknowledged the petitioner's ownership of the sold shares. The amount was ordered released on superdari subject to furnishing a guarantee of equivalent value, with no final determination on actual ownership pending adjudication on merits.
HC determined the petitioner was entitled to release of Rs.15.90 lakhs realized from share sales. The court found the petitioner genuinely placed shares for sale through Respondent No. 2, with fraud occurring at Respondent's end through Amit Jain and potentially Ashish Aggarwal Jain. No evidence implicated the petitioner in the fraudulent transaction. Despite inconsistencies in the petitioner's statements regarding share numbers, the court acknowledged the petitioner's ownership of the sold shares. The amount was ordered released on superdari subject to furnishing a guarantee of equivalent value, with no final determination on actual ownership pending adjudication on merits.
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