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 HC affirmed that the Respondent, a freight forwarder, acted as the final forwarder who issued an airway bill in the name of a non-existent firm, arranged airline space without conducting KYC, and caused use of forged documents in the illegal export of prohibited goods. The HC held that a monetary penalty of Rs.10 lakh-already imposed and sustained by the Tribunal-adequately addresses the Respondent's culpability. The Court declined to impose the additional penal consequence under Section 114AA of the Customs Act, 1962, which would have equated to five times the value of the goods. The appeal is dismissed and the Rs.10 lakh penalty is maintained.
The HC affirmed that the Respondent, a freight forwarder, acted as the final forwarder who issued an airway bill in the name of a non-existent firm, arranged airline space without conducting KYC, and caused use of forged documents in the illegal export of prohibited goods. The HC held that a monetary penalty of Rs.10 lakh-already imposed and sustained by the Tribunal-adequately addresses the Respondent's culpability. The Court declined to impose the additional penal consequence under Section 114AA of the Customs Act, 1962, which would have equated to five times the value of the goods. The appeal is dismissed and the Rs.10 lakh penalty is maintained.
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