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 appellate tribunal allowed the application for a 45-day extension beyond the 465-day period under exceptional circumstances. The adjudicating authority had previously granted an extension until 27.04.2025, during which substantial resolution steps, including completion of e-voting and plan approval, occurred. The tribunal found that the adjudicating authority erred by rejecting the extension application without considering that the matter was effectively resolved before 03.06.2025, despite the parties' lack of knowledge of the court's order at that time. Given the resolution progress and the grievances of the appellants, resolution professional, and majority financial creditor, the extension was deemed justified. Consequently, the appeal was allowed, and the extension application granted.
The appellate tribunal allowed the application for a 45-day extension beyond the 465-day period under exceptional circumstances. The adjudicating authority had previously granted an extension until 27.04.2025, during which substantial resolution steps, including completion of e-voting and plan approval, occurred. The tribunal found that the adjudicating authority erred by rejecting the extension application without considering that the matter was effectively resolved before 03.06.2025, despite the parties' lack of knowledge of the court's order at that time. Given the resolution progress and the grievances of the appellants, resolution professional, and majority financial creditor, the extension was deemed justified. Consequently, the appeal was allowed, and the extension application granted.
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