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 of belated claims that are reflected in the corporate debtor's books and information memorandum requires that those claim details be furnished to the Resolution Applicant so an addendum to the resolution plan can be prepared and placed before the Committee of Creditors; the Tribunal applied the reasoning in Puneet Kaur and distinguished Pooja Mehra, rejecting that mere adjustment of unclaimed units satisfied the claim where payment was not applied to the unit. Outcome: RP to submit recorded claimant details to the RA, RA to prepare an addendum for CoC consideration, and the Adjudicating Authority to consider the addendum and CoC minutes at plan approval.
Admission of belated claims that are reflected in the corporate debtor's books and information memorandum requires that those claim details be furnished to the Resolution Applicant so an addendum to the resolution plan can be prepared and placed before the Committee of Creditors; the Tribunal applied the reasoning in Puneet Kaur and distinguished Pooja Mehra, rejecting that mere adjustment of unclaimed units satisfied the claim where payment was not applied to the unit. Outcome: RP to submit recorded claimant details to the RA, RA to prepare an addendum for CoC consideration, and the Adjudicating Authority to consider the addendum and CoC minutes at plan approval.
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