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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Approved resolution plans under the IBC extinguish pre-CIRP tax demands, and belated claims cannot be enforced against the corporate debtor once the plan is sanctioned on a clean-slate basis. Applying that principle, the High Court directed the Revenue to give effect to the NCLT-approved plan, delete all pre-resolution-plan demands from the Income Tax Portal, recompute the petitioner's liability or refund, and issue any consequential refund within the stipulated time.
Approved resolution plans under the IBC extinguish pre-CIRP tax demands, and belated claims cannot be enforced against the corporate debtor once the plan is sanctioned on a clean-slate basis. Applying that principle, the High Court directed the Revenue to give effect to the NCLT-approved plan, delete all pre-resolution-plan demands from the Income Tax Portal, recompute the petitioner's liability or refund, and issue any consequential refund within the stipulated time.
Note: It is a system-generated summary and is for quick reference only.