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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Contravention of Sections 8(1) and 9(1)(f)(i) of the Foreign Exchange Regulation Act, 1973 - receiving foreign exchange payments in 1996-97 through fake export documents without actual exports. Adjudicating Authority imposed penalties of Rs.2 lakhs for Section 8(1) contravention and Rs.3 lakhs for Section 9(1)(f)(i) contravention. Show Cause Notice issued in 2002, over 22 years ago. Appellant deposited Rs.2 lakhs against total penalty of Rs.5 lakhs. Considering case peculiarities and counsel leaving penalty reduction open, Appellate Tribunal reduced total penalty to Rs.2 lakhs, Rs.1 lakh each for Sections 8(1) and 9(1)(f)(i) contraventions. Deposited amount treated as satisfying reduced penalty, no further deposit required.
Contravention of Sections 8(1) and 9(1)(f)(i) of the Foreign Exchange Regulation Act, 1973 - receiving foreign exchange payments in 1996-97 through fake export documents without actual exports. Adjudicating Authority imposed penalties of Rs.2 lakhs for Section 8(1) contravention and Rs.3 lakhs for Section 9(1)(f)(i) contravention. Show Cause Notice issued in 2002, over 22 years ago. Appellant deposited Rs.2 lakhs against total penalty of Rs.5 lakhs. Considering case peculiarities and counsel leaving penalty reduction open, Appellate Tribunal reduced total penalty to Rs.2 lakhs, Rs.1 lakh each for Sections 8(1) and 9(1)(f)(i) contraventions. Deposited amount treated as satisfying reduced penalty, no further deposit required.
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