Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
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Fixed deposit receipts kept as margin money for expired bank guarantees were treated as assets of the corporate debtor, and therefore passed to the successful resolution applicant after implementation of the resolution plan. The tribunal held that the information memorandum is meant to disclose available assets and liabilities, but omission of an asset from it does not, by itself, vest that asset in the erstwhile Committee of Creditors or defeat the resolution applicant's title. It distinguished extinguishment of claims under the resolution plan from transfer of ownership of later-discovered assets, and held that the banks had no right to adjust the FDR proceeds after full implementation of the plan.
Fixed deposit receipts kept as margin money for expired bank guarantees were treated as assets of the corporate debtor, and therefore passed to the successful resolution applicant after implementation of the resolution plan. The tribunal held that the information memorandum is meant to disclose available assets and liabilities, but omission of an asset from it does not, by itself, vest that asset in the erstwhile Committee of Creditors or defeat the resolution applicant's title. It distinguished extinguishment of claims under the resolution plan from transfer of ownership of later-discovered assets, and held that the banks had no right to adjust the FDR proceeds after full implementation of the plan.
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