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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Claims founded on assessments completed after the moratorium are barred from admission in CIRP under the moratorium doctrine; accordingly postmoratorium EPFO assessmentbased demands cannot be admitted and the appeal challenging the resolution plan was dismissed. The resolution professional had recorded the provident fund claim despite improper format, included it in the Information Memorandum, and the resolution plan provided a lower payout; the tribunal treated the inclusion and commercial judgment of the committee of creditors as operative and distinguishable from precedent where claims were ignored. Absence of contemporaneous PF deductions in company records supported exclusion of the postmoratorium assessment claim.
Claims founded on assessments completed after the moratorium are barred from admission in CIRP under the moratorium doctrine; accordingly postmoratorium EPFO assessmentbased demands cannot be admitted and the appeal challenging the resolution plan was dismissed. The resolution professional had recorded the provident fund claim despite improper format, included it in the Information Memorandum, and the resolution plan provided a lower payout; the tribunal treated the inclusion and commercial judgment of the committee of creditors as operative and distinguishable from precedent where claims were ignored. Absence of contemporaneous PF deductions in company records supported exclusion of the postmoratorium assessment claim.
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