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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Penalty u/s 114(i) - illegal activities with the tenants - tenant was using the property, which was rented out by the petitioner for storing turtles and tortoises. - It is quite possible that the tenant was engaged in illegal activities, which would be violation of the Customs Act, 1962, Wildlife Protection Act, 1972, CITES and any other enactments. Imposition of penalty of Rs.4,50,00,000/- makes the appellate remedy illusory for a small time agriculturist, who had the misfortune of renting out the property to a person, who had actually indulged in illegal export - HC
Penalty u/s 114(i) - illegal activities with the tenants - tenant was using the property, which was rented out by the petitioner for storing turtles and tortoises. - It is quite possible that the tenant was engaged in illegal activities, which would be violation of the Customs Act, 1962, Wildlife Protection Act, 1972, CITES and any other enactments. Imposition of penalty of Rs.4,50,00,000/- makes the appellate remedy illusory for a small time agriculturist, who had the misfortune of renting out the property to a person, who had actually indulged in illegal export - HC
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