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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Order u/s 19(1) of FEMA imposing penalty for contravention of Section 42(1) challenged. Transactions carried out in violation of FEMA provisions. Liability of person in-charge and responsible for company's conduct of business. Deeming clause holds in-charge liable, with proviso excluding those without knowledge and exercising due diligence. Appellant claimed not being in-charge of compliances, with safeguards and policy in place. Adjudicating Authority silent on Appellant's role and plea. Appellant proved contravention without knowledge and due diligence exercised. Impugned order set aside by Appellate Tribunal in favor of Appellant.
Order u/s 19(1) of FEMA imposing penalty for contravention of Section 42(1) challenged. Transactions carried out in violation of FEMA provisions. Liability of person in-charge and responsible for company's conduct of business. Deeming clause holds in-charge liable, with proviso excluding those without knowledge and exercising due diligence. Appellant claimed not being in-charge of compliances, with safeguards and policy in place. Adjudicating Authority silent on Appellant's role and plea. Appellant proved contravention without knowledge and due diligence exercised. Impugned order set aside by Appellate Tribunal in favor of Appellant.
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