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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Imposition of penalty u/s 112 (a) of the Customs Act, 1962 - Who is the importer - No deponent has clearly mentioned that they were fully aware of the fact of the appellants being the owner of the goods and have merely mentioned that they were told so by the other concerned persons. There is virtually no evidence in the present case so as to show that the appellant were the actual importer of the goods - No penalty - AT
Imposition of penalty u/s 112 (a) of the Customs Act, 1962 - Who is the importer - No deponent has clearly mentioned that they were fully aware of the fact of the appellants being the owner of the goods and have merely mentioned that they were told so by the other concerned persons. There is virtually no evidence in the present case so as to show that the appellant were the actual importer of the goods - No penalty - AT
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