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 dismissed the appeal, holding that contempt proceedings cannot be extended beyond the ambit of the principal proceedings before the Principal Special Court; the interim status quo order dated 19.07.2024 must be read restrictively in relation to "transactions" within the execution context and does not operate as an absolute bar on amalgamation proceedings under Section 230. The Tribunal held that non-disclosure of the status quo order by entities that were not parties to the principal or contempt proceedings does not constitute suppression of a material fact where no gravamen arises, and that the Intervention Application was correctly refused because the Appellant failed to demonstrate a legally cognizable interest under the proviso to Section 230(4).
NCLAT dismissed the appeal, holding that contempt proceedings cannot be extended beyond the ambit of the principal proceedings before the Principal Special Court; the interim status quo order dated 19.07.2024 must be read restrictively in relation to "transactions" within the execution context and does not operate as an absolute bar on amalgamation proceedings under Section 230. The Tribunal held that non-disclosure of the status quo order by entities that were not parties to the principal or contempt proceedings does not constitute suppression of a material fact where no gravamen arises, and that the Intervention Application was correctly refused because the Appellant failed to demonstrate a legally cognizable interest under the proviso to Section 230(4).
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