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 partially allowed the appeal, setting aside the Rs. 10 lakh penalty and land confiscation order related to the first contravention. The tribunal maintained penalties for two additional contraventions: (1) receiving foreign remittances not in the name of specific directors, and (2) failing to submit statements to RBI within 30 days. The court distinguished between corporate entities and individual directors, rejecting the appellant's argument about ownership. The land situated in plot no. 313/1, Village Siolim (8075 sq. mtr.) was restored to the appellant, while other penalties remained in effect, effectively providing a nuanced partial relief to the appellant company.
The AT partially allowed the appeal, setting aside the Rs. 10 lakh penalty and land confiscation order related to the first contravention. The tribunal maintained penalties for two additional contraventions: (1) receiving foreign remittances not in the name of specific directors, and (2) failing to submit statements to RBI within 30 days. The court distinguished between corporate entities and individual directors, rejecting the appellant's argument about ownership. The land situated in plot no. 313/1, Village Siolim (8075 sq. mtr.) was restored to the appellant, while other penalties remained in effect, effectively providing a nuanced partial relief to the appellant company.
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