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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SC held that the notice dated 10.06.2015 satisfied statutory requirements and afforded a fair opportunity to answer alleged contraventions; no statutory mandate existed for a second show-cause notice proposing penalty. Pursuant to the deeming provision in Section 48, the enterprise's key officers were liable as persons "in charge of and responsible" and could be subject to corollary directions incidental to behavioural remedies imposed primarily on the enterprise. The Commission must apply the doctrine of proportionality when imposing remedies under Section 27. The Commission's findings dated 08.09.2015 are restored in entirety and the appeal is allowed.
SC held that the notice dated 10.06.2015 satisfied statutory requirements and afforded a fair opportunity to answer alleged contraventions; no statutory mandate existed for a second show-cause notice proposing penalty. Pursuant to the deeming provision in Section 48, the enterprise's key officers were liable as persons "in charge of and responsible" and could be subject to corollary directions incidental to behavioural remedies imposed primarily on the enterprise. The Commission must apply the doctrine of proportionality when imposing remedies under Section 27. The Commission's findings dated 08.09.2015 are restored in entirety and the appeal is allowed.
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