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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CESTAT upheld penalty under Section 112(b) of Customs Act against appellant for involvement in cigarette smuggling racket. While appellant retracted initial statement, subsequent testimony on 04.08.2015 reaffirmed earlier admissions. Multiple witness statements corroborated appellant's role in arranging CHA, transport, storage and container tampering. Tribunal rejected retraction as afterthought but reduced penalty from Rs. 50,00,000 to Rs. 25,00,000 considering proportionality to appellant's role. Finding established connivance in smuggling based on consistent testimonial evidence and appellant's own admission, CESTAT maintained liability while moderating quantum of penalty.
CESTAT upheld penalty under Section 112(b) of Customs Act against appellant for involvement in cigarette smuggling racket. While appellant retracted initial statement, subsequent testimony on 04.08.2015 reaffirmed earlier admissions. Multiple witness statements corroborated appellant's role in arranging CHA, transport, storage and container tampering. Tribunal rejected retraction as afterthought but reduced penalty from Rs. 50,00,000 to Rs. 25,00,000 considering proportionality to appellant's role. Finding established connivance in smuggling based on consistent testimonial evidence and appellant's own admission, CESTAT maintained liability while moderating quantum of penalty.
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