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 High Court considered an application for compounding contravention under FEMA. The petitioner filed Form FC-TRS belatedly, leading to investigations and complaints. The Court noted that Rule 8(2) of the Compounding Proceeding Rules requires the Compounding Authority to pass an order within 180 days and afford all concerned parties an opportunity to be heard. The Court found that investigations on money laundering charges were ongoing, preventing compounding proceedings. Rule 4(1) empowers the first respondent to compound contraventions, except those related to suspected money laundering. A proviso added to Rule 8(2) prohibits compounding contraventions suspected of terror financing or affecting national sovereignty, remitting such cases to the Adjudicating Authority. The compounding application was returned due to the proviso, which does not allow compounding of contraventions suspected of money laundering.
The High Court considered an application for compounding contravention under FEMA. The petitioner filed Form FC-TRS belatedly, leading to investigations and complaints. The Court noted that Rule 8(2) of the Compounding Proceeding Rules requires the Compounding Authority to pass an order within 180 days and afford all concerned parties an opportunity to be heard. The Court found that investigations on money laundering charges were ongoing, preventing compounding proceedings. Rule 4(1) empowers the first respondent to compound contraventions, except those related to suspected money laundering. A proviso added to Rule 8(2) prohibits compounding contraventions suspected of terror financing or affecting national sovereignty, remitting such cases to the Adjudicating Authority. The compounding application was returned due to the proviso, which does not allow compounding of contraventions suspected of money laundering.
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