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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The AT upheld penalties against a Research Analyst for multiple regulatory violations. The appellant failed to sign and date research reports, maintain proper records of recommendations made on WhatsApp/Telegram channels, and establish independence between research activities and other business ventures. The tribunal rejected arguments that WhatsApp/Telegram publications did not constitute "public appearances" requiring disclosure. The AT found the appellant violated arm's length requirements by operating multiple business divisions (Chartered Accountancy, Spiritual Teaching, and News Broadcasting) while functioning as a Research Analyst. Penalties under Sections 15A(c), 15EB, and 15HA totaling 15 lakhs were confirmed for misleading information and multiple regulatory breaches.
The AT upheld penalties against a Research Analyst for multiple regulatory violations. The appellant failed to sign and date research reports, maintain proper records of recommendations made on WhatsApp/Telegram channels, and establish independence between research activities and other business ventures. The tribunal rejected arguments that WhatsApp/Telegram publications did not constitute "public appearances" requiring disclosure. The AT found the appellant violated arm's length requirements by operating multiple business divisions (Chartered Accountancy, Spiritual Teaching, and News Broadcasting) while functioning as a Research Analyst. Penalties under Sections 15A(c), 15EB, and 15HA totaling 15 lakhs were confirmed for misleading information and multiple regulatory breaches.
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