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 duty-free scrips fraudulently manipulated in the customs EDI system render the entire transaction void ab initio. The tribunal rejected the importer's plea of non-involvement in forgery, affirming that fraud vitiates everything. The extended period of limitation was correctly invoked, and the demand for customs duty, interest, and penalties was upheld. The appeals were dismissed, confirming the Commissioner's original order and establishing that importers cannot escape liability when forged instruments are used for customs clearance.
CESTAT held that duty-free scrips fraudulently manipulated in the customs EDI system render the entire transaction void ab initio. The tribunal rejected the importer's plea of non-involvement in forgery, affirming that fraud vitiates everything. The extended period of limitation was correctly invoked, and the demand for customs duty, interest, and penalties was upheld. The appeals were dismissed, confirming the Commissioner's original order and establishing that importers cannot escape liability when forged instruments are used for customs clearance.
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