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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AT determined appellant violated FEMA, 1999 by illegally possessing unaccounted foreign currency without authorization from RBI. The tribunal found appellant's explanation for foreign currency possession unconvincing and identified mala fide intentions. The seized foreign currency equivalent to INR 3,30,82,775.28 was confiscated under Section 13(2), with a penalty of Rs. One lakh imposed. Additionally, the payment of USD 22,000 to an NRI without RBI permission constituted a breach of Section 3(b), resulting in a supplementary penalty of Rs. 10,000. The appeal was dismissed, and the Adjudicating Authority's original order was fully upheld.
AT determined appellant violated FEMA, 1999 by illegally possessing unaccounted foreign currency without authorization from RBI. The tribunal found appellant's explanation for foreign currency possession unconvincing and identified mala fide intentions. The seized foreign currency equivalent to INR 3,30,82,775.28 was confiscated under Section 13(2), with a penalty of Rs. One lakh imposed. Additionally, the payment of USD 22,000 to an NRI without RBI permission constituted a breach of Section 3(b), resulting in a supplementary penalty of Rs. 10,000. The appeal was dismissed, and the Adjudicating Authority's original order was fully upheld.
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