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 appellant, Container Corporation of India, was granted custodianship as a Customs Cargo Service Provider (CCSP) under the Handling of Cargo in Customs Areas Regulations (HCCAR), 2009. The approval of CCSP is subject to conditions under Regulation 5, and responsibilities are outlined in Regulation 6. During the renewal process, discrepancies were found regarding non-compliance with Regulations 5(1)(i)(c)(f)(g)(n) and clause (iii), leading to penalties under Regulation 12(8) of HCCAR, 2009. Additionally, the custodian operated from an area not notified u/s 8 of the Customs Act, 1962, violating Sections 45, 7, and 8, resulting in a penalty u/s 117. The Appellate Tribunal upheld the penalties but reduced the amounts to Rs. 10,000/- under Regulation 12(8) of HCCAR, 2009, and Rs. 25,000/- u/s 117 of the Customs Act, 1962.
The appellant, Container Corporation of India, was granted custodianship as a Customs Cargo Service Provider (CCSP) under the Handling of Cargo in Customs Areas Regulations (HCCAR), 2009. The approval of CCSP is subject to conditions under Regulation 5, and responsibilities are outlined in Regulation 6. During the renewal process, discrepancies were found regarding non-compliance with Regulations 5(1)(i)(c)(f)(g)(n) and clause (iii), leading to penalties under Regulation 12(8) of HCCAR, 2009. Additionally, the custodian operated from an area not notified u/s 8 of the Customs Act, 1962, violating Sections 45, 7, and 8, resulting in a penalty u/s 117. The Appellate Tribunal upheld the penalties but reduced the amounts to Rs. 10,000/- under Regulation 12(8) of HCCAR, 2009, and Rs. 25,000/- u/s 117 of the Customs Act, 1962.
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