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 allowed appeals of three appellants and set aside the impugned order, holding that the Department failed to prove contravention of Section 3(a) of the Foreign Exchange Management Act, 1999. The Tribunal found no admissible evidence of foreign remittance; reliance on police/visa verification and disputed correspondence did not establish actual outward remittance. The Respondent failed to obtain corroborative materials (e.g., bank statements) to discharge the evidentiary burden, and the allegation could not stand on presumption or hypothesis. Claims regarding EURO funds in a foreign trust were unproven. Consequently, the penalty and enhancement sought by the Department were quashed and the appeals of the three appellants were allowed.
The AT allowed appeals of three appellants and set aside the impugned order, holding that the Department failed to prove contravention of Section 3(a) of the Foreign Exchange Management Act, 1999. The Tribunal found no admissible evidence of foreign remittance; reliance on police/visa verification and disputed correspondence did not establish actual outward remittance. The Respondent failed to obtain corroborative materials (e.g., bank statements) to discharge the evidentiary burden, and the allegation could not stand on presumption or hypothesis. Claims regarding EURO funds in a foreign trust were unproven. Consequently, the penalty and enhancement sought by the Department were quashed and the appeals of the three appellants were allowed.
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