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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Whether challenged rights issues, consequent allotments and share transfers constituted oppression or mismanagement was considered; Tribunal held the Board acted within the Articles of Association and statutory powers in increasing authorised capital and making rights allotments, the contractual and statutory conditions were satisfied, and therefore the actions did not amount to oppression or mismanagement. An interim/anticipatory prayer to restrain loss of promoter status was dismissed as premature because it rested on apprehension without a concrete act; the appellants were left free to seek relief if an actual oppressive or mismanagement act occurs. Appeal dismissed.
Whether challenged rights issues, consequent allotments and share transfers constituted oppression or mismanagement was considered; Tribunal held the Board acted within the Articles of Association and statutory powers in increasing authorised capital and making rights allotments, the contractual and statutory conditions were satisfied, and therefore the actions did not amount to oppression or mismanagement. An interim/anticipatory prayer to restrain loss of promoter status was dismissed as premature because it rested on apprehension without a concrete act; the appellants were left free to seek relief if an actual oppressive or mismanagement act occurs. Appeal dismissed.
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