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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IBBI specifies mandatory formats under Regulation 38(3A) of the CIRP Regulations for inclusion in every resolution plan: (i) a "Statement of Beneficial Ownership" capturing prescribed particulars for each beneficial owner, with beneficial ownership determined under Rule 9(3) of the PMLA (Maintenance of Records) Rules, 2005 and requiring disclosure of intermediate entities; this standardises beneficial ownership disclosures and supports verification, with misrepresentation attracting consequences under applicable law. (ii) A notarised affidavit by the prospective resolution applicant's authorised signatory declaring eligibility or ineligibility for Section 32A benefit, with brief supporting facts; this compels an express Section 32A status declaration. The resolution professional must ensure both documents form part of the plan placed before the CoC and filed under Section 30(6).
IBBI specifies mandatory formats under Regulation 38(3A) of the CIRP Regulations for inclusion in every resolution plan: (i) a "Statement of Beneficial Ownership" capturing prescribed particulars for each beneficial owner, with beneficial ownership determined under Rule 9(3) of the PMLA (Maintenance of Records) Rules, 2005 and requiring disclosure of intermediate entities; this standardises beneficial ownership disclosures and supports verification, with misrepresentation attracting consequences under applicable law. (ii) A notarised affidavit by the prospective resolution applicant's authorised signatory declaring eligibility or ineligibility for Section 32A benefit, with brief supporting facts; this compels an express Section 32A status declaration. The resolution professional must ensure both documents form part of the plan placed before the CoC and filed under Section 30(6).
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