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 declined to initiate contempt proceedings, holding that although the Respondent breached the court-recorded undertaking pursuant to the settlement, the shortfall (approximately Rs.70-75 lakh of Rs.5.45 crore) principally stems from financial incapacity rather than wilful and contumacious disobedience; consequently, the threshold for criminal standard contempt under Section 2(b) of the Contempt of Courts Act, 1971, is not met. The Respondent is granted until 31.12.2025 to pay the outstanding principal with 12% interest as per the undertaking; failure to comply will entitle the Complainants to pursue execution of the undertaking. Petition disposed.
The HC declined to initiate contempt proceedings, holding that although the Respondent breached the court-recorded undertaking pursuant to the settlement, the shortfall (approximately Rs.70-75 lakh of Rs.5.45 crore) principally stems from financial incapacity rather than wilful and contumacious disobedience; consequently, the threshold for criminal standard contempt under Section 2(b) of the Contempt of Courts Act, 1971, is not met. The Respondent is granted until 31.12.2025 to pay the outstanding principal with 12% interest as per the undertaking; failure to comply will entitle the Complainants to pursue execution of the undertaking. Petition disposed.
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