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 customs broker's appeal against license revocation, security deposit forfeiture, and penalty imposition. The tribunal found that while the broker failed to discharge obligations under Regulation 10(d), (e) & (n) of CBLR 2018 and attempted to aid an importer in bypassing policy restrictions, the revenue failed to prove violations warranting license cancellation. Though the broker acted in good faith, certain unexplained grey areas demonstrated insufficient diligence in client obligations and justifying the "H" card authorization. CESTAT modified the impugned order by setting aside license revocation and security deposit forfeiture while reducing the penalty to Rs.5,000 as deterrent measure. Appeal disposed.
CESTAT partially allowed the customs broker's appeal against license revocation, security deposit forfeiture, and penalty imposition. The tribunal found that while the broker failed to discharge obligations under Regulation 10(d), (e) & (n) of CBLR 2018 and attempted to aid an importer in bypassing policy restrictions, the revenue failed to prove violations warranting license cancellation. Though the broker acted in good faith, certain unexplained grey areas demonstrated insufficient diligence in client obligations and justifying the "H" card authorization. CESTAT modified the impugned order by setting aside license revocation and security deposit forfeiture while reducing the penalty to Rs.5,000 as deterrent measure. Appeal disposed.
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