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 CHA License - appellant failed to verify the address at which the two clients operated and that requirement of ‘know your customer (KYC)’ was entirely different - The appellant was accused of breaching obligations related to verifying client identity and operations at the declared address. Despite the appellant's argument of compliance with KYC norms and reliance on precedent, the tribunal found that they failed to exercise due diligence in verifying client antecedents, especially in the diamond trade. While setting aside certain penalties, the tribunal upheld the forfeiture of the security deposit, emphasizing the importance of regulatory compliance and diligence in customs brokerage.
Revocation of CHA License - appellant failed to verify the address at which the two clients operated and that requirement of ‘know your customer (KYC)’ was entirely different - The appellant was accused of breaching obligations related to verifying client identity and operations at the declared address. Despite the appellant's argument of compliance with KYC norms and reliance on precedent, the tribunal found that they failed to exercise due diligence in verifying client antecedents, especially in the diamond trade. While setting aside certain penalties, the tribunal upheld the forfeiture of the security deposit, emphasizing the importance of regulatory compliance and diligence in customs brokerage.
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