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 adjudicated a foreign exchange contravention case involving unauthorized receipt of funds from outside India. The tribunal found violations under Sections 3(c) and 3(d) of the 1999 Act based on documentary evidence and corroborated statements. The original penalties of Rs. 9 crore and Rs. 1 crore were substantially reduced to Rs. 2.75 crore and Rs. 25 lakhs respectively, considering the case's age. The tribunal directed respondent to adjust Rs. 1 crore from the confiscated amount of Rs. 1,10,95,000, with excess funds to be returned to the appellant. The appellant's prior deposit of Rs. 90 lakhs and bank guarantee of Rs. 1.10 crore were also considered in the final disposition.
AT adjudicated a foreign exchange contravention case involving unauthorized receipt of funds from outside India. The tribunal found violations under Sections 3(c) and 3(d) of the 1999 Act based on documentary evidence and corroborated statements. The original penalties of Rs. 9 crore and Rs. 1 crore were substantially reduced to Rs. 2.75 crore and Rs. 25 lakhs respectively, considering the case's age. The tribunal directed respondent to adjust Rs. 1 crore from the confiscated amount of Rs. 1,10,95,000, with excess funds to be returned to the appellant. The appellant's prior deposit of Rs. 90 lakhs and bank guarantee of Rs. 1.10 crore were also considered in the final disposition.
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