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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The text addresses whether the adjudicatory authority may extend the Personal Insolvency Resolution Process (PIRP) beyond procedural timeline lapses while the statutory moratorium remains time-capped. It reasons that procedural timelines in the applicable regulation (including the 120 day filing requirement) are directory, not automatically fatal, and that the authority retains jurisdiction to permit extensions where stakeholders authorise and sufficient reasons exist; however the moratorium itself cannot be extended beyond its statutory outer limit. The conclusion reversed the rejection of extension applications and permitted adjudication of the repayment plan on the extended PIRP timeline.
The text addresses whether the adjudicatory authority may extend the Personal Insolvency Resolution Process (PIRP) beyond procedural timeline lapses while the statutory moratorium remains time-capped. It reasons that procedural timelines in the applicable regulation (including the 120 day filing requirement) are directory, not automatically fatal, and that the authority retains jurisdiction to permit extensions where stakeholders authorise and sufficient reasons exist; however the moratorium itself cannot be extended beyond its statutory outer limit. The conclusion reversed the rejection of extension applications and permitted adjudication of the repayment plan on the extended PIRP timeline.
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