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 affirmed the Adjudicating Authority's directive requiring the appellant to lift the lien and release a fixed deposit of Rs.27.60 crores (with interest) held in the name of the corporate debtor. The Tribunal held the appellant's refusal to release the FD on account of alleged dues of a related group company was unjustified: the lien letter authorised retention only for amounts due from the corporate debtor itself, singly or jointly, and no facility existed against which the corporate debtor was liable. Consequently, the Adjudicating Authority's order was upheld and the appeal was dismissed.
NCLAT affirmed the Adjudicating Authority's directive requiring the appellant to lift the lien and release a fixed deposit of Rs.27.60 crores (with interest) held in the name of the corporate debtor. The Tribunal held the appellant's refusal to release the FD on account of alleged dues of a related group company was unjustified: the lien letter authorised retention only for amounts due from the corporate debtor itself, singly or jointly, and no facility existed against which the corporate debtor was liable. Consequently, the Adjudicating Authority's order was upheld and the appeal was dismissed.
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