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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AT analyzed the interplay between IBC, PMLA, and SARFAESI Act, holding that Section 14 moratorium does not preclude property attachment under PMLA. The tribunal rejected appellant's challenge, finding no merit in arguments regarding statutory precedence. Section 32A immunity was inapplicable as resolution plan conditions were not satisfied. The attachment of properties remains valid, with the court emphasizing that different statutes serve distinct legislative purposes. Consequently, the appellate tribunal dismissed the appeal, affirming the original attachment order and maintaining the enforcement mechanism under PMLA.
AT analyzed the interplay between IBC, PMLA, and SARFAESI Act, holding that Section 14 moratorium does not preclude property attachment under PMLA. The tribunal rejected appellant's challenge, finding no merit in arguments regarding statutory precedence. Section 32A immunity was inapplicable as resolution plan conditions were not satisfied. The attachment of properties remains valid, with the court emphasizing that different statutes serve distinct legislative purposes. Consequently, the appellate tribunal dismissed the appeal, affirming the original attachment order and maintaining the enforcement mechanism under PMLA.
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