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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Confiscation - redemption fine - penalty - The appellant has contravened the provisions of Section 17 and 46(4) of the Act by intentionally filing wrong declarations and by their acts of omissions and commissions had rendered the goods liable for confiscation under Section 111(l) and 111(m) of the Act. The appellant filing the Bill of Entry under self-assessment was duty bound to submit true and correct details. - No interference is called for in the quantum of redemption fine - AT
Confiscation - redemption fine - penalty - The appellant has contravened the provisions of Section 17 and 46(4) of the Act by intentionally filing wrong declarations and by their acts of omissions and commissions had rendered the goods liable for confiscation under Section 111(l) and 111(m) of the Act. The appellant filing the Bill of Entry under self-assessment was duty bound to submit true and correct details. - No interference is called for in the quantum of redemption fine - AT
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