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 HC vacated the interim restraint against the applicants, finding that while the SFIO report and board minutes contain material suggesting awareness and attendance at meetings during the period of alleged irregularity, they do not establish ex facie culpability sufficient to dismiss claims under Section 542(1). The court declined to strike the applicants from the array or to dismiss or stay misfeasance proceedings, holding that triable issues remain as to knowledge and participation and that evidence may later be lacking; leave was granted to reapply if evidence ultimately absolves them. The application was disposed of, with the balance of convenience weighed against continuation of the interim order.
The HC vacated the interim restraint against the applicants, finding that while the SFIO report and board minutes contain material suggesting awareness and attendance at meetings during the period of alleged irregularity, they do not establish ex facie culpability sufficient to dismiss claims under Section 542(1). The court declined to strike the applicants from the array or to dismiss or stay misfeasance proceedings, holding that triable issues remain as to knowledge and participation and that evidence may later be lacking; leave was granted to reapply if evidence ultimately absolves them. The application was disposed of, with the balance of convenience weighed against continuation of the interim order.
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