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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Liability of directors for company tax in liquidation was examined with emphasis on control by a liquidator and recovery from the companys credit ledger; the court found no justification to attach individual directors bank accounts where the company is under liquidator control, and the attachment was ordered vacated. The applicability of recoveries under GST enactments and operation of the credit ledger was recognized as satisfying tax recovery against the company, and directors were granted liberty to apply to respondents to be extricated from the impugned liability, with leave to file within 15 days.
Liability of directors for company tax in liquidation was examined with emphasis on control by a liquidator and recovery from the companys credit ledger; the court found no justification to attach individual directors bank accounts where the company is under liquidator control, and the attachment was ordered vacated. The applicability of recoveries under GST enactments and operation of the credit ledger was recognized as satisfying tax recovery against the company, and directors were granted liberty to apply to respondents to be extricated from the impugned liability, with leave to file within 15 days.
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