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 appellate tribunal held that the revocation of the customs broker's license based on alleged violations of Regulations 10(d), 10(m), 10(o), and 10(q) of the Customs Brokers Regulation, 2018, was unsustainable. The broker had duly advised the client to comply with the Customs Act and reported discrepancies to authorities, negating breach of Regulation 10(d). No delay or inefficiency was proven under Regulation 10(m). Allegations of non-cooperation and unauthorized premises usage under Regulation 10(o) were unsupported, and absence due to illness did not constitute non-cooperation. Under Regulation 10(q), the broker cooperated with investigations, and no evidence indicated evasion of summons. Consequently, the tribunal found the allegations unsubstantiated and allowed the appeal, reinstating the broker's license.
The appellate tribunal held that the revocation of the customs broker's license based on alleged violations of Regulations 10(d), 10(m), 10(o), and 10(q) of the Customs Brokers Regulation, 2018, was unsustainable. The broker had duly advised the client to comply with the Customs Act and reported discrepancies to authorities, negating breach of Regulation 10(d). No delay or inefficiency was proven under Regulation 10(m). Allegations of non-cooperation and unauthorized premises usage under Regulation 10(o) were unsupported, and absence due to illness did not constitute non-cooperation. Under Regulation 10(q), the broker cooperated with investigations, and no evidence indicated evasion of summons. Consequently, the tribunal found the allegations unsubstantiated and allowed the appeal, reinstating the broker's license.
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