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 HC upheld the Punjab and Maharashtra Co-Operative Bank Ltd. amalgamation scheme with Unity Small Finance Bank, finding no constitutional, statutory or procedural infirmity in the approval under the Banking Regulation Act. It held that judicial review of banking and economic policy is limited, and the RBI's decision was a public-interest measure justified by the bank's severe erosion of net worth and need to protect depositors. The Court also rejected challenges to depositor classification, staggered repayment and reduced interest, holding that retail and institutional depositors formed a valid distinction and that Section 45 permitted modification of depositor rights. Procedural objections on consultation, hearing and supersession of the board were also rejected.
The HC upheld the Punjab and Maharashtra Co-Operative Bank Ltd. amalgamation scheme with Unity Small Finance Bank, finding no constitutional, statutory or procedural infirmity in the approval under the Banking Regulation Act. It held that judicial review of banking and economic policy is limited, and the RBI's decision was a public-interest measure justified by the bank's severe erosion of net worth and need to protect depositors. The Court also rejected challenges to depositor classification, staggered repayment and reduced interest, holding that retail and institutional depositors formed a valid distinction and that Section 45 permitted modification of depositor rights. Procedural objections on consultation, hearing and supersession of the board were also rejected.
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