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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Alteration of acquisition structure expressly permitted by terms of an approved resolution plan and approved by the committee of creditors or implementation monitoring committee does not violate the time limit for completion of the corporate insolvency resolution process where the originally approved plan was submitted to the adjudicating authority within the statutory timeline; modification approved thereafter and placed before the authority is not a timeline breach. Operational creditors, including employees, are entitled to the amounts provided in the approved plan and employee provident fund and gratuity dues must be paid in full notwithstanding any capped earmark in the plan.
Alteration of acquisition structure expressly permitted by terms of an approved resolution plan and approved by the committee of creditors or implementation monitoring committee does not violate the time limit for completion of the corporate insolvency resolution process where the originally approved plan was submitted to the adjudicating authority within the statutory timeline; modification approved thereafter and placed before the authority is not a timeline breach. Operational creditors, including employees, are entitled to the amounts provided in the approved plan and employee provident fund and gratuity dues must be paid in full notwithstanding any capped earmark in the plan.
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