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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Tribunal affirmed the Adjudicating Authority's rejection of an insolvency petition on the ground that the Corporate Debtor had raised a bona fide pre-existing dispute prior to the demand notice. Applying the plausible contention test, the Tribunal held the debtor's pre-demand communication denying privity, seeking detailed transaction particulars, and the invoices' lack of corroborative customer/delivery data amounted to a dispute requiring further investigation and not a patently spurious defence; accordingly the petition was correctly dismissed as barred by the pre-existing dispute doctrine.
Tribunal affirmed the Adjudicating Authority's rejection of an insolvency petition on the ground that the Corporate Debtor had raised a bona fide pre-existing dispute prior to the demand notice. Applying the plausible contention test, the Tribunal held the debtor's pre-demand communication denying privity, seeking detailed transaction particulars, and the invoices' lack of corroborative customer/delivery data amounted to a dispute requiring further investigation and not a patently spurious defence; accordingly the petition was correctly dismissed as barred by the pre-existing dispute doctrine.
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