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 partially allowed the appeal, setting aside the revocation of customs broker's licence and forfeiture of security deposit. The tribunal found the penalties disproportionately severe, noting insufficient evidence of misconduct under regulation 10(d) of Customs Broker Licensing Regulations, 2018. While acknowledging potential procedural irregularities in export goods valuation, the tribunal determined no conclusive proof of intentional wrongdoing by the customs broker. The order was modified to mitigate the original punitive measures, maintaining the underlying penalty imposed by the lower authority.
CESTAT partially allowed the appeal, setting aside the revocation of customs broker's licence and forfeiture of security deposit. The tribunal found the penalties disproportionately severe, noting insufficient evidence of misconduct under regulation 10(d) of Customs Broker Licensing Regulations, 2018. While acknowledging potential procedural irregularities in export goods valuation, the tribunal determined no conclusive proof of intentional wrongdoing by the customs broker. The order was modified to mitigate the original punitive measures, maintaining the underlying penalty imposed by the lower authority.
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