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dismissed the Company Appeal for want of merit and declined condonation relief, holding that the Appellant, having withdrawn the related Company Appeal arising from IA No. 419/2024, lacks locus to impugn the order on IA No. 805/2024. The Tribunal observed the relief sought in IA No. 805/2024 mirrored that in IA No. 419/2024 and was bound by directions issued on IA No. 419/2024. Further, the Appellant participated in the final round of the challenge process without contemporaneous objection and the resolution plan has been approved under Section 30(6) read with Section 60(5) of the IBC, leaving no subsisting cause of action; appeal dismissed.
NCLAT dismissed the Company Appeal for want of merit and declined condonation relief, holding that the Appellant, having withdrawn the related Company Appeal arising from IA No. 419/2024, lacks locus to impugn the order on IA No. 805/2024. The Tribunal observed the relief sought in IA No. 805/2024 mirrored that in IA No. 419/2024 and was bound by directions issued on IA No. 419/2024. Further, the Appellant participated in the final round of the challenge process without contemporaneous objection and the resolution plan has been approved under Section 30(6) read with Section 60(5) of the IBC, leaving no subsisting cause of action; appeal dismissed.
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