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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The case involved confiscation of imported goods u/s 111(d) of CA 1962, re-exportation, redemption fine, and penalty u/s 112(a). Goods were imported in contravention of EPR, 1986 making them 'prohibited goods'. Confiscation u/s 111(d) precedes redemption u/s 125. Re-export permission is an administrative process post redemption. No redemption fine on re-exported goods as title vests with govt. Penalty u/s 112(a) is for breach of duty, not cured by re-export. Appellate Tribunal upheld the order, rejecting appellant's claims.
The case involved confiscation of imported goods u/s 111(d) of CA 1962, re-exportation, redemption fine, and penalty u/s 112(a). Goods were imported in contravention of EPR, 1986 making them 'prohibited goods'. Confiscation u/s 111(d) precedes redemption u/s 125. Re-export permission is an administrative process post redemption. No redemption fine on re-exported goods as title vests with govt. Penalty u/s 112(a) is for breach of duty, not cured by re-export. Appellate Tribunal upheld the order, rejecting appellant's claims.
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