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 involves an offence under FEMA with regard to the business conduct of a company. The liability of a director for contravention of provisions depends on their role in the company, not just their designation. The main person in charge was actively involved in the company's affairs, while other directors were not. One retired director was directly responsible for accounts in foreign banks. The respondents, although directors, were not actively involved in decision-making or in charge of the company's affairs. Lack of evidence showing their responsibility for the company's conduct led the Appellate Tribunal to dismiss the Revision Petition.
The case involves an offence under FEMA with regard to the business conduct of a company. The liability of a director for contravention of provisions depends on their role in the company, not just their designation. The main person in charge was actively involved in the company's affairs, while other directors were not. One retired director was directly responsible for accounts in foreign banks. The respondents, although directors, were not actively involved in decision-making or in charge of the company's affairs. Lack of evidence showing their responsibility for the company's conduct led the Appellate Tribunal to dismiss the Revision Petition.
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