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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AT directed denial of waiver of the statutory pre-deposit: the appellant's application for waiver was dismissed and the appellant was ordered to deposit 25% of the penalty amount as the condition of pre-deposit. The AT relied on documentary disclosures recovered during search and statements under the relevant statute implicating the appellant in receipt of Rs. 12.90 crore and transfers amounting to Rs. 12.50 crore purportedly routed to secure foreign TTs, finding prima facie material suggestive of bogus exports and hawala-linked remittances. The appellant's unsubstantiated claim of financial hardship and asserted bona fide export sales was insufficient to dispel the pre-deposit requirement.
AT directed denial of waiver of the statutory pre-deposit: the appellant's application for waiver was dismissed and the appellant was ordered to deposit 25% of the penalty amount as the condition of pre-deposit. The AT relied on documentary disclosures recovered during search and statements under the relevant statute implicating the appellant in receipt of Rs. 12.90 crore and transfers amounting to Rs. 12.50 crore purportedly routed to secure foreign TTs, finding prima facie material suggestive of bogus exports and hawala-linked remittances. The appellant's unsubstantiated claim of financial hardship and asserted bona fide export sales was insufficient to dispel the pre-deposit requirement.
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