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...
Page of 4828
Press 'Enter' after typing page number.
161 to 180 of 96556 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
The AT held that the penalty imposed on the Exchange is...
Penalty on exchange vacated for lack of evidence that exchange authorized subsidiaries' investments; Regulations 43(1) 2012 and 38(2) 2018 inapplicable
Contents
Summary
Note
Bookmark
Share
✓ Copied successfully !
Print
Print Options
For full text, please login
Login to TaxTMI
Verification Pending
The Email Id has not been verified. Click on the link we have sent on
The AT held that the penalty imposed on the Exchange is unsustainable and set aside the impugned order. The Tribunal found no material demonstrating that the Exchange itself authorized investments or acquisitions by its subsidiaries; only the subsidiaries made the investments. Absent a board resolution or evidence attributing those acts to the Exchange, the Tribunal concluded that penal provisions must be construed strictly and that the impugned provisions do not permit imputation of a subsidiary's independent activities to its principal. Consequently, Regulation 43(1) of the 2012 Regulations and Regulation 38(2) of the 2018 Regulations were held inapplicable and the Regulatory authority's penalty was vacated.
The AT held that the penalty imposed on the Exchange is unsustainable and set aside the impugned order. The Tribunal found no material demonstrating that the Exchange itself authorized investments or acquisitions by its subsidiaries; only the subsidiaries made the investments. Absent a board resolution or evidence attributing those acts to the Exchange, the Tribunal concluded that penal provisions must be construed strictly and that the impugned provisions do not permit imputation of a subsidiary's independent activities to its principal. Consequently, Regulation 43(1) of the 2012 Regulations and Regulation 38(2) of the 2018 Regulations were held inapplicable and the Regulatory authority's penalty was vacated.
Note: It is a system-generated summary and is for quick reference only.