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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HC upheld the Adjudicating Authority's opinion formation under Rule 4(3) of FEMA Rules against M/s. Xiaomi Technology India Private Limited regarding unauthorized royalty payments to group entities and Qualcomm without RBI approval. The court declined to interfere with the opinion formation stage, holding that strong suspicion suffices for proceeding to adjudication, and detailed reasoning is not mandatorily required at this preliminary stage. However, HC directed respondents to furnish complete investigation records including non-relied documents and missing pages to enable effective defense during adjudication proceedings under Rule 4(4). The writ petitions were disposed of with directions for document disclosure while allowing adjudication to proceed.
HC upheld the Adjudicating Authority's opinion formation under Rule 4(3) of FEMA Rules against M/s. Xiaomi Technology India Private Limited regarding unauthorized royalty payments to group entities and Qualcomm without RBI approval. The court declined to interfere with the opinion formation stage, holding that strong suspicion suffices for proceeding to adjudication, and detailed reasoning is not mandatorily required at this preliminary stage. However, HC directed respondents to furnish complete investigation records including non-relied documents and missing pages to enable effective defense during adjudication proceedings under Rule 4(4). The writ petitions were disposed of with directions for document disclosure while allowing adjudication to proceed.
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