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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CESTAT allowed the appeal and set aside both impugned orders: the revocation of the customs broker licence, forfeiture of the security/pre-deposit and imposition of penalty were held unsustainable. The Tribunal found allegations under Regulations 10(b), 10(d), 10(m), 10(n) and 10(q) of the CBLR, 2018 unsubstantiated - noting the broker transacted at the customs station, possessed authentic exporter identifiers (IEC, GSTIN, PAN, Aadhaar), cooperated with authorities, and that no evidence showed willful alteration, delay, or lack of due diligence sufficient to merit disciplinary sanction. Consequential monetary measures were quashed and the licence revocation set aside.
CESTAT allowed the appeal and set aside both impugned orders: the revocation of the customs broker licence, forfeiture of the security/pre-deposit and imposition of penalty were held unsustainable. The Tribunal found allegations under Regulations 10(b), 10(d), 10(m), 10(n) and 10(q) of the CBLR, 2018 unsubstantiated - noting the broker transacted at the customs station, possessed authentic exporter identifiers (IEC, GSTIN, PAN, Aadhaar), cooperated with authorities, and that no evidence showed willful alteration, delay, or lack of due diligence sufficient to merit disciplinary sanction. Consequential monetary measures were quashed and the licence revocation set aside.
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