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 penalty on the Director of the Company - Valuation of imported goods - import of luxury vehicles by misusing the Transfer of Residence (TR) Scheme - The Tribunal observed that the company involved in purchasing the vehicle was an independent legal entity, and the penalties primarily targeted the company rather than the individual appellants. - It was noted that there were no clear allegations against the individual appellants regarding their direct involvement in the import violation. The penalties primarily targeted the company's actions. - the Tribunal set aside the penalties imposed on the appellants, stating that they were eligible for consequential relief.
Levy of penalty on the Director of the Company - Valuation of imported goods - import of luxury vehicles by misusing the Transfer of Residence (TR) Scheme - The Tribunal observed that the company involved in purchasing the vehicle was an independent legal entity, and the penalties primarily targeted the company rather than the individual appellants. - It was noted that there were no clear allegations against the individual appellants regarding their direct involvement in the import violation. The penalties primarily targeted the company's actions. - the Tribunal set aside the penalties imposed on the appellants, stating that they were eligible for consequential relief.
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