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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Appellant was found guilty of contravening Sections 8(3) read with 8(4) and Sections 8(3) read with 8(4) read with Section 64 of FERA for over-invoicing imported books and unauthorised foreign exchange remittances through proprietorship firms. Although not the mastermind, Appellant had knowledge of the fraudulent scheme and allowed the main accused to use proprietorship names for imports. Based on recorded statements and available records, Appellate Tribunal established Appellant's involvement in the contravention. The penalty was reduced to Rs. 2 Lakhs, which was already pre-deposited. The blocked amount of Rs. 60,859.52 in Appellant's firm's account was directed to be released along with interest.
Appellant was found guilty of contravening Sections 8(3) read with 8(4) and Sections 8(3) read with 8(4) read with Section 64 of FERA for over-invoicing imported books and unauthorised foreign exchange remittances through proprietorship firms. Although not the mastermind, Appellant had knowledge of the fraudulent scheme and allowed the main accused to use proprietorship names for imports. Based on recorded statements and available records, Appellate Tribunal established Appellant's involvement in the contravention. The penalty was reduced to Rs. 2 Lakhs, which was already pre-deposited. The blocked amount of Rs. 60,859.52 in Appellant's firm's account was directed to be released along with interest.
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