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 HC quashed attachment orders dated 19.01.2013, 17.02.2014, and 01.05.2015 against directors' personal properties under the Gujarat Value Added Tax Act, 2003. Following precedent in MR Choksi, the court reiterated that corporate veil cannot be lifted without strong factual foundation, which was absent in this case. The court emphasized that personal properties of directors cannot be attached to secure company dues, as this issue is no longer res integra. The respondents failed to establish any basis for disregarding the company's separate legal personality to pursue directors personally. Petition allowed.
The HC quashed attachment orders dated 19.01.2013, 17.02.2014, and 01.05.2015 against directors' personal properties under the Gujarat Value Added Tax Act, 2003. Following precedent in MR Choksi, the court reiterated that corporate veil cannot be lifted without strong factual foundation, which was absent in this case. The court emphasized that personal properties of directors cannot be attached to secure company dues, as this issue is no longer res integra. The respondents failed to establish any basis for disregarding the company's separate legal personality to pursue directors personally. Petition allowed.
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