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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Smuggling - Absolute confiscation of foreign currency seized from the Appellant u/s 113(d),(e) & (h) of the Customs Act - The Tribunal found that there was only a venial breach of Section 113(d) of the Customs Act, implying that the Appellant had the intention to export but had not entered the customs area. - The Tribunal acknowledged that while the Appellant had intentions to travel outside India and possessed foreign currency, absolute confiscation was not justified. Instead, the Tribunal upheld confiscation under Section 113(d) of the Customs Act but allowed redemption upon payment of a fine.
Smuggling - Absolute confiscation of foreign currency seized from the Appellant u/s 113(d),(e) & (h) of the Customs Act - The Tribunal found that there was only a venial breach of Section 113(d) of the Customs Act, implying that the Appellant had the intention to export but had not entered the customs area. - The Tribunal acknowledged that while the Appellant had intentions to travel outside India and possessed foreign currency, absolute confiscation was not justified. Instead, the Tribunal upheld confiscation under Section 113(d) of the Customs Act but allowed redemption upon payment of a fine.
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