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 a customs broker's appeal against license revocation, finding the licensing authority incorrectly applied regulations 10(d) and 10(e) of Customs Brokers Licensing Regulations, 2018. The Tribunal confirmed violation of regulation 10(n) as the broker failed to properly verify the exporter's premises, conducting only cursory document checks while the declared address showed no business operations. The Tribunal determined that complete revocation of license and security deposit forfeiture was disproportionate to the single regulatory breach. The penalty of Rs. 50,000 was maintained as sufficient sanction, while the license revocation and security deposit forfeiture were set aside.
CESTAT upheld a customs broker's appeal against license revocation, finding the licensing authority incorrectly applied regulations 10(d) and 10(e) of Customs Brokers Licensing Regulations, 2018. The Tribunal confirmed violation of regulation 10(n) as the broker failed to properly verify the exporter's premises, conducting only cursory document checks while the declared address showed no business operations. The Tribunal determined that complete revocation of license and security deposit forfeiture was disproportionate to the single regulatory breach. The penalty of Rs. 50,000 was maintained as sufficient sanction, while the license revocation and security deposit forfeiture were set aside.
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