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 upheld the Ld. AA's order, affirming that the Respondents' contravention of Section 6(3)(b) of FEMA was a technical breach, as the mandatory FC-GPR form was submitted within the prescribed period. The tribunal noted the absence of any communication to the Respondents regarding the breach, which was directed solely to the AD Bank. The Respondents acknowledged the error concerning a surname discrepancy and paid the penalty imposed by the Ld. AA. The AT concluded that the penalty was reasonable, refusing to enhance it, thereby confirming the order as just, fair, and in accordance with FEMA provisions.
The AT upheld the Ld. AA's order, affirming that the Respondents' contravention of Section 6(3)(b) of FEMA was a technical breach, as the mandatory FC-GPR form was submitted within the prescribed period. The tribunal noted the absence of any communication to the Respondents regarding the breach, which was directed solely to the AD Bank. The Respondents acknowledged the error concerning a surname discrepancy and paid the penalty imposed by the Ld. AA. The AT concluded that the penalty was reasonable, refusing to enhance it, thereby confirming the order as just, fair, and in accordance with FEMA provisions.
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