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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Suspension of Customs Broker’s Licence - Regulation 16(1) of the CBLR, 2018 - facts and circumstances of the case pending further investigation and decision on revocation of licence or imposition of penalty under CBLR, 2018 - allegation is that CB had no idea of the valuation of the consignments and never tried to know the real value of the Ball Bearings - over- valuation of exports to defraud the Exchequer by getting the very high Input Tax Credit and export related incentives - Allegation are not provided - the impugned order confirming the suspension of the licence of the Appellant cannot be sustained - AT
Suspension of Customs Broker’s Licence - Regulation 16(1) of the CBLR, 2018 - facts and circumstances of the case pending further investigation and decision on revocation of licence or imposition of penalty under CBLR, 2018 - allegation is that CB had no idea of the valuation of the consignments and never tried to know the real value of the Ball Bearings - over- valuation of exports to defraud the Exchequer by getting the very high Input Tax Credit and export related incentives - Allegation are not provided - the impugned order confirming the suspension of the licence of the Appellant cannot be sustained - AT
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