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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ITAT dismissed appeals filed by directors of a company undergoing liquidation for lack of locus standi and improper verification. Following NCLT's initiation of Corporate Insolvency Resolution Process and appointment of liquidator, directors lost authority to pursue appeals on behalf of the company. Although liquidator issued Letter of Authority to counsel, proper Form 36 duly signed and verified by liquidator was not filed despite liquidation proceedings continuing for five years. Appeals were held not maintainable due to improper verification and failure to substitute required documentation. ITAT granted liquidator liberty to file fresh Form 36 with condonation petition if continuation of proceedings desired, subject to coordinate Bench's discretion regarding recall of dismissal order.
ITAT dismissed appeals filed by directors of a company undergoing liquidation for lack of locus standi and improper verification. Following NCLT's initiation of Corporate Insolvency Resolution Process and appointment of liquidator, directors lost authority to pursue appeals on behalf of the company. Although liquidator issued Letter of Authority to counsel, proper Form 36 duly signed and verified by liquidator was not filed despite liquidation proceedings continuing for five years. Appeals were held not maintainable due to improper verification and failure to substitute required documentation. ITAT granted liquidator liberty to file fresh Form 36 with condonation petition if continuation of proceedings desired, subject to coordinate Bench's discretion regarding recall of dismissal order.
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