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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Imposition of penalties u/s 114 (iii) and 114A on employees / manager of CHA - benami shipping bills - The Tribunal found that the appellant knowingly filed benami shipping bills with mis-declared information, facilitating fraudulent claims of drawback. This act rendered the goods liable for confiscation. Despite the appellant's assertion of innocence, the Tribunal held that he failed to exercise due diligence expected of a CHA manager. Filing shipping bills without verifying the authenticity of the exporter's documents amounted to complicity in the fraudulent scheme.
Imposition of penalties u/s 114 (iii) and 114A on employees / manager of CHA - benami shipping bills - The Tribunal found that the appellant knowingly filed benami shipping bills with mis-declared information, facilitating fraudulent claims of drawback. This act rendered the goods liable for confiscation. Despite the appellant's assertion of innocence, the Tribunal held that he failed to exercise due diligence expected of a CHA manager. Filing shipping bills without verifying the authenticity of the exporter's documents amounted to complicity in the fraudulent scheme.
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