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 held that the revocation of the appellant's Customs Broker License and forfeiture of security deposit were unjustified. The Tribunal found that the alleged breaches of regulations 10(d) and 10(e) of Customs Broker Licensing Regulations, 2018 were not established by the facts presented. The failure to file declarations regarding drawback claims was deemed a technical irregularity, particularly as customs authorities had not noticed it themselves. The magnitude of potentially ineligible drawback claims across seven shipping bills did not warrant the severe penalties imposed. The Tribunal set aside the license revocation and security deposit forfeiture while maintaining the penalty under regulation 18, disposing of the appeal accordingly.
CESTAT held that the revocation of the appellant's Customs Broker License and forfeiture of security deposit were unjustified. The Tribunal found that the alleged breaches of regulations 10(d) and 10(e) of Customs Broker Licensing Regulations, 2018 were not established by the facts presented. The failure to file declarations regarding drawback claims was deemed a technical irregularity, particularly as customs authorities had not noticed it themselves. The magnitude of potentially ineligible drawback claims across seven shipping bills did not warrant the severe penalties imposed. The Tribunal set aside the license revocation and security deposit forfeiture while maintaining the penalty under regulation 18, disposing of the appeal accordingly.
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