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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Levy of redemption fine and penalty - valuation of imported goods - brass scrap - The appellate tribunal noted the absence of a market survey conducted by the adjudicating authority for quantifying the redemption fine. However, considering that the appellant did not contest the enhancement of the goods' value and lack of evidence of deliberate misdeclaration, the tribunal reduced the redemption fine to Rs. 2,50,000 and penalty amount reduced to Rs. 20,000.
Levy of redemption fine and penalty - valuation of imported goods - brass scrap - The appellate tribunal noted the absence of a market survey conducted by the adjudicating authority for quantifying the redemption fine. However, considering that the appellant did not contest the enhancement of the goods' value and lack of evidence of deliberate misdeclaration, the tribunal reduced the redemption fine to Rs. 2,50,000 and penalty amount reduced to Rs. 20,000.
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