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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Goods were mis-declared in baggage declaration for export, rendering them liable for confiscation. Penalties imposed under Customs Act: Section 114 on individuals involved in filing airway bills using fictitious company name, enabling export fraud. Section 114AA on individuals responsible for mis-declarations in baggage declaration filed for customs purposes, with penalties based on their roles and knowledge. Appellate Tribunal upheld some penalties, modified or set aside others based on evidence of involvement and applicability of specific provisions. Determination made regarding appropriate penalties commensurate with the nature of offenses and roles played by different individuals in the smuggling attempt.
Goods were mis-declared in baggage declaration for export, rendering them liable for confiscation. Penalties imposed under Customs Act: Section 114 on individuals involved in filing airway bills using fictitious company name, enabling export fraud. Section 114AA on individuals responsible for mis-declarations in baggage declaration filed for customs purposes, with penalties based on their roles and knowledge. Appellate Tribunal upheld some penalties, modified or set aside others based on evidence of involvement and applicability of specific provisions. Determination made regarding appropriate penalties commensurate with the nature of offenses and roles played by different individuals in the smuggling attempt.
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