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, upholding the tribunal's order that the appellant materially breached the approved resolution plan by failing to pay the required upfront amount and subsequent instalments, resulting in non-implementation. The CoC had earlier contemplated liquidation but, upon the appellant's request, permitted submission of a fresh resolution plan which later secured 100% CoC approval. The record established the appellant lacked funds to meet the upfront fee, sought extensions twice, yet did not remit any amount within stipulated timelines. Given the appellant's repeated default and the reasoned findings below, the appellate challenge was devoid of merit and the impugned order refusing relief was affirmed.
NCLAT dismissed the appeal, upholding the tribunal's order that the appellant materially breached the approved resolution plan by failing to pay the required upfront amount and subsequent instalments, resulting in non-implementation. The CoC had earlier contemplated liquidation but, upon the appellant's request, permitted submission of a fresh resolution plan which later secured 100% CoC approval. The record established the appellant lacked funds to meet the upfront fee, sought extensions twice, yet did not remit any amount within stipulated timelines. Given the appellant's repeated default and the reasoned findings below, the appellate challenge was devoid of merit and the impugned order refusing relief was affirmed.
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