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 dismissed the petition challenging the rejection of a request for relaxation under Rule 9C read with Section 72A regarding carry-forward of losses from amalgamated companies. The court determined that the petitioner failed to achieve the required production capacity (50%) even during the requested three-year extension period. The court emphasized that Section 72A's objective is not merely to encourage corporate restructuring but to extend benefits only where amalgamating companies' industrial undertakings are genuinely revived or continued. The petitioner's multiple requests to modify conditions-first seeking time extensions and later requesting reduced production thresholds (from 50% to 36-42%)-were found unmeritorious, as the application was filed just one day before the expiry of the four-year post-amalgamation period.
HC dismissed the petition challenging the rejection of a request for relaxation under Rule 9C read with Section 72A regarding carry-forward of losses from amalgamated companies. The court determined that the petitioner failed to achieve the required production capacity (50%) even during the requested three-year extension period. The court emphasized that Section 72A's objective is not merely to encourage corporate restructuring but to extend benefits only where amalgamating companies' industrial undertakings are genuinely revived or continued. The petitioner's multiple requests to modify conditions-first seeking time extensions and later requesting reduced production thresholds (from 50% to 36-42%)-were found unmeritorious, as the application was filed just one day before the expiry of the four-year post-amalgamation period.
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