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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A liquidation claim filed after a 787-day delay was rejected because Regulation 12(2)(b) requires claims to be lodged or updated within the prescribed time, and insolvency law treats timeliness as central to the liquidation process. Even if the timeline were treated as directory, an inordinate delay still needed a satisfactory explanation, which was absent here. The pendency or abatement of customs proceedings did not bar filing the claim before the liquidator, and a government department was not entitled to any special indulgence in condonation of delay. Entertaining the belated claim at an advanced stage would disrupt the liquidation process, so the rejection was upheld.
A liquidation claim filed after a 787-day delay was rejected because Regulation 12(2)(b) requires claims to be lodged or updated within the prescribed time, and insolvency law treats timeliness as central to the liquidation process. Even if the timeline were treated as directory, an inordinate delay still needed a satisfactory explanation, which was absent here. The pendency or abatement of customs proceedings did not bar filing the claim before the liquidator, and a government department was not entitled to any special indulgence in condonation of delay. Entertaining the belated claim at an advanced stage would disrupt the liquidation process, so the rejection was upheld.
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