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 dismissed the appeal and authorized the liquidator of the insolvent company to seek leave from the Special Judge, PMLA under s.8(7), PMLA, 2002 to auction specified properties notwithstanding parallel insolvency proceedings under the IBC. The AT held that auction proceeds may be apportioned to satisfy secured creditors and that any surplus must be deposited as a fixed deposit receipt (FDR) with the ED pursuant to an undertaking. The deposited FDR, if any, will remain subject to adjudication and disposal by the Special Judge, PMLA after conclusion of the trial. Appeal disposed.
AT dismissed the appeal and authorized the liquidator of the insolvent company to seek leave from the Special Judge, PMLA under s.8(7), PMLA, 2002 to auction specified properties notwithstanding parallel insolvency proceedings under the IBC. The AT held that auction proceeds may be apportioned to satisfy secured creditors and that any surplus must be deposited as a fixed deposit receipt (FDR) with the ED pursuant to an undertaking. The deposited FDR, if any, will remain subject to adjudication and disposal by the Special Judge, PMLA after conclusion of the trial. Appeal disposed.
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