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 company contravened Section 8(1) of Foreign Exchange Regulation Act, 1973 by acquiring and transferring foreign exchange of US$ 28,26,433.26 without requisite permission, and borrowing foreign exchange of US$ 3,33,025 and lb7,068.38. AT upheld findings of violation, reduced penalty on company to 25% already deposited considering case's antiquity and facts. However, AT set aside penalty on Mr. Ishaat Hussain finding no evidence of his involvement in company's affairs regarding aircraft purchase.
Appellant company contravened Section 8(1) of Foreign Exchange Regulation Act, 1973 by acquiring and transferring foreign exchange of US$ 28,26,433.26 without requisite permission, and borrowing foreign exchange of US$ 3,33,025 and lb7,068.38. AT upheld findings of violation, reduced penalty on company to 25% already deposited considering case's antiquity and facts. However, AT set aside penalty on Mr. Ishaat Hussain finding no evidence of his involvement in company's affairs regarding aircraft purchase.
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