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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No penalty was sustained against a Customs Broker for alleged movement of imported goods before out-of-charge because the vehicles carrying the goods remained within the Land Customs Station and were available for drawal of samples by DRI. On that factual basis, the alleged breach of permitting movement without out-of-charge was not made out. The Tribunal also noted that the appellant had already been discharged in the CBLR proceedings, making the impugned penalty unwarranted. The penalties were set aside and the appeals were allowed.
No penalty was sustained against a Customs Broker for alleged movement of imported goods before out-of-charge because the vehicles carrying the goods remained within the Land Customs Station and were available for drawal of samples by DRI. On that factual basis, the alleged breach of permitting movement without out-of-charge was not made out. The Tribunal also noted that the appellant had already been discharged in the CBLR proceedings, making the impugned penalty unwarranted. The penalties were set aside and the appeals were allowed.
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