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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Revocation of Customs Broker License - forfeiture of security deposit - the appellant had not interacted with the proprietor of the importing entity is on record; consequently, it would not be wrong to conclude that the several documents of identity and location had not been verified. Though that, of itself, may not be taken as having contributed to misdeclaration, it is, nonetheless, a breach of obligation. - Order of revocation set aside - However, levy of penalty confirmed - AT
Revocation of Customs Broker License - forfeiture of security deposit - the appellant had not interacted with the proprietor of the importing entity is on record; consequently, it would not be wrong to conclude that the several documents of identity and location had not been verified. Though that, of itself, may not be taken as having contributed to misdeclaration, it is, nonetheless, a breach of obligation. - Order of revocation set aside - However, levy of penalty confirmed - AT
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