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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Interest on an electricity security deposit was claimed by a successful auction purchaser on the basis that prior electricity liabilities stood extinguished and that regulatory interest was payable. The NCLAT held that the liquidation-related concessions merely directed restoration of supply and continuation of the security deposit in the corporate debtor's name, and did not create any entitlement to interest. Further, the interest-adjustment mechanism under the applicable electricity regulations operated through annual billing, but supply had been permanently disconnected years earlier and the deposit was withheld against dues resolved through separate HC-directed payments; the auction purchaser, entering in 2021, could not assert interest from the 2016-17 disconnection period. The appeal was dismissed.
Interest on an electricity security deposit was claimed by a successful auction purchaser on the basis that prior electricity liabilities stood extinguished and that regulatory interest was payable. The NCLAT held that the liquidation-related concessions merely directed restoration of supply and continuation of the security deposit in the corporate debtor's name, and did not create any entitlement to interest. Further, the interest-adjustment mechanism under the applicable electricity regulations operated through annual billing, but supply had been permanently disconnected years earlier and the deposit was withheld against dues resolved through separate HC-directed payments; the auction purchaser, entering in 2021, could not assert interest from the 2016-17 disconnection period. The appeal was dismissed.
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