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 partly allowed the appeal concerning a Customs Broker's license revocation. The Tribunal held that the appellant violated Regulations 10(a) by failing to produce client authorization when requested and 10(q) by not cooperating with investigations. However, the appellant did not violate Regulations 10(d) and 10(n), as customs brokers cannot be expected to verify the physical existence of exporters when government-issued documents are presumed genuine. Applying the doctrine of proportionality, CESTAT modified the order by setting aside the license revocation and security deposit forfeiture while upholding the Rs. 50,000 penalty, finding this sufficient to meet the ends of justice.
CESTAT partly allowed the appeal concerning a Customs Broker's license revocation. The Tribunal held that the appellant violated Regulations 10(a) by failing to produce client authorization when requested and 10(q) by not cooperating with investigations. However, the appellant did not violate Regulations 10(d) and 10(n), as customs brokers cannot be expected to verify the physical existence of exporters when government-issued documents are presumed genuine. Applying the doctrine of proportionality, CESTAT modified the order by setting aside the license revocation and security deposit forfeiture while upholding the Rs. 50,000 penalty, finding this sufficient to meet the ends of justice.
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