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 SC dismissed the challenge to the arbitral award and upheld the grant of even pendente lite interest against the respondent. The Court held the arbitral tribunal's power to award pendente lite interest is not ousted absent an agreement that expressly or by necessary implication bars such relief; a contractual clause prohibiting interest on delayed payments did not, read as a whole, preclude pendente lite interest. The Court found no legal error in the award warranting interference, and post-award interest accorded with the statutory framework extant then. The petition by the appellant seeking impugnation of the award was dismissed and the arbitral award affirmed.
The SC dismissed the challenge to the arbitral award and upheld the grant of even pendente lite interest against the respondent. The Court held the arbitral tribunal's power to award pendente lite interest is not ousted absent an agreement that expressly or by necessary implication bars such relief; a contractual clause prohibiting interest on delayed payments did not, read as a whole, preclude pendente lite interest. The Court found no legal error in the award warranting interference, and post-award interest accorded with the statutory framework extant then. The petition by the appellant seeking impugnation of the award was dismissed and the arbitral award affirmed.
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