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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Admission under the Insolvency and Bankruptcy Code (section reference omitted) was contested on date-of-default and limitation grounds but the dispute turned on an executed MOU, acknowledged receipt of funds, continuous failure to perform, and an arbitral award rendered as an executable decree. The award's finality and enforceability was treated as operative for limitation (a subsequent suo motu writ order was invoked in support). Non appearance and ex parte proceedings before the arbitral forum and tribunal informed findings on the corporate debtor's conduct and intention, and the appellate challenge was dismissed as lacking merit.
Admission under the Insolvency and Bankruptcy Code (section reference omitted) was contested on date-of-default and limitation grounds but the dispute turned on an executed MOU, acknowledged receipt of funds, continuous failure to perform, and an arbitral award rendered as an executable decree. The award's finality and enforceability was treated as operative for limitation (a subsequent suo motu writ order was invoked in support). Non appearance and ex parte proceedings before the arbitral forum and tribunal informed findings on the corporate debtor's conduct and intention, and the appellate challenge was dismissed as lacking merit.
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