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 dismissed the appeal regarding loan assignment to respondent No.7 without prior notice to appellants. The court held that assignment dated 27.12.2022 was valid as law requires only intimation, not prior notice, which was provided. Appellants' account was classified as SMA on 14.11.2022 for amounts overdue 1-30 days, constituting default under RBI circulars governing 2019-2023 assignments. The court determined that RBI circular operation itself serves as constructive notice to borrowers regarding timely payment obligations to avoid SMA classification. Under master circular dated 24.09.2021 updated 05.12.2022, lenders may transfer stressed loans including NPAs or SMAs. The assignment complied with regulatory framework as the account qualified as stressed asset eligible for transfer to asset reconstruction company.
The HC dismissed the appeal regarding loan assignment to respondent No.7 without prior notice to appellants. The court held that assignment dated 27.12.2022 was valid as law requires only intimation, not prior notice, which was provided. Appellants' account was classified as SMA on 14.11.2022 for amounts overdue 1-30 days, constituting default under RBI circulars governing 2019-2023 assignments. The court determined that RBI circular operation itself serves as constructive notice to borrowers regarding timely payment obligations to avoid SMA classification. Under master circular dated 24.09.2021 updated 05.12.2022, lenders may transfer stressed loans including NPAs or SMAs. The assignment complied with regulatory framework as the account qualified as stressed asset eligible for transfer to asset reconstruction company.
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