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 petitioner approached the High Court challenging three orders passed by the adjudicating authority, appellate authority, and revisionary authority regarding non-realization of foreign exchange on exported goods for which drawback was sanctioned. The High Court found the petitioner's attempt to hide the truth and suppress material facts from the authorities, as well as the Court. The petition was dismissed with a cost of Rs. 5 lakhs to be paid to the Commissioner of Customs, Mumbai, within two weeks, failing which the respondents could recover the amount with 18% interest along with the amount recoverable under the original order. The Court held that any party approaching it should come with clean hands, and the petitioner's hands were muddied in this case.
The petitioner approached the High Court challenging three orders passed by the adjudicating authority, appellate authority, and revisionary authority regarding non-realization of foreign exchange on exported goods for which drawback was sanctioned. The High Court found the petitioner's attempt to hide the truth and suppress material facts from the authorities, as well as the Court. The petition was dismissed with a cost of Rs. 5 lakhs to be paid to the Commissioner of Customs, Mumbai, within two weeks, failing which the respondents could recover the amount with 18% interest along with the amount recoverable under the original order. The Court held that any party approaching it should come with clean hands, and the petitioner's hands were muddied in this case.
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