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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NCLAT adjudicated an appeal challenging the modification of the 'Appointed Date' in an amalgamation scheme. The tribunal found that the lower NCLT improperly altered the appointed date without providing reasons or opportunity for the appellant to respond, thereby violating principles of natural justice. The NCLAT held that the appointed date shall remain as originally specified in the scheme's clauses, rejecting the NCLT's unilateral modification. The tribunal emphasized that changing the appointed date arbitrarily could significantly impact financial calculations and legal implications. Consequently, the appeal was allowed, and the impugned order was modified to reinstate the original appointed date as per the scheme's provisions.
NCLAT adjudicated an appeal challenging the modification of the 'Appointed Date' in an amalgamation scheme. The tribunal found that the lower NCLT improperly altered the appointed date without providing reasons or opportunity for the appellant to respond, thereby violating principles of natural justice. The NCLAT held that the appointed date shall remain as originally specified in the scheme's clauses, rejecting the NCLT's unilateral modification. The tribunal emphasized that changing the appointed date arbitrarily could significantly impact financial calculations and legal implications. Consequently, the appeal was allowed, and the impugned order was modified to reinstate the original appointed date as per the scheme's provisions.
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