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 no penalties were imposable under FEMA, 1999 for two export transactions involving short-realization of export proceeds. For the first transaction through M.V. Vincentia, the appellant demonstrated bona fide efforts to mitigate losses and obtain RBI approval, with no mandatory requirement for penalty. In the second transaction via MV Riva, excess payment was already received, and respondents failed to substantiate claims of negligence. Consequently, penalties against the corporate entity and individual appellants were set aside, recognizing procedural compliance and absence of intentional contravention.
AT determined no penalties were imposable under FEMA, 1999 for two export transactions involving short-realization of export proceeds. For the first transaction through M.V. Vincentia, the appellant demonstrated bona fide efforts to mitigate losses and obtain RBI approval, with no mandatory requirement for penalty. In the second transaction via MV Riva, excess payment was already received, and respondents failed to substantiate claims of negligence. Consequently, penalties against the corporate entity and individual appellants were set aside, recognizing procedural compliance and absence of intentional contravention.
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