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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Approval of a resolution plan that treated specified third-party/guarantor land as assets of the corporate debtor and set aside a fraudulent, undervalued lease deed was upheld; the adjudicatory authoritys prior orders approving the plan and cancelling the lease were held to be final and binding, and consequential directions flowing from those approvals were sustained. Challenges that inclusion of third-party property exceeded the authority or was exclusively a civil remedy were rejected, and the appellate challenge was dismissed for lack of merit, preserving the operative effect of the resolution plan and avoidance of the preferential/fraudulent transaction.
Approval of a resolution plan that treated specified third-party/guarantor land as assets of the corporate debtor and set aside a fraudulent, undervalued lease deed was upheld; the adjudicatory authoritys prior orders approving the plan and cancelling the lease were held to be final and binding, and consequential directions flowing from those approvals were sustained. Challenges that inclusion of third-party property exceeded the authority or was exclusively a civil remedy were rejected, and the appellate challenge was dismissed for lack of merit, preserving the operative effect of the resolution plan and avoidance of the preferential/fraudulent transaction.
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