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 dismissed the appeals and upheld the regulatory order finding fraudulent issuance of GDRs to create a false impression of USD 24.25 million foreign subscription. The tribunal concluded the first appellant and the company materially altered and acquiesced to a pledge agreement with a foreign bank, evidencing control over funds and subsequent interest remittal, notwithstanding absence of genuine receipt of subscription monies. The AT affirmed restraint from securities market access for three years and imposition of monetary penalties for contraventions of statutory provisions and PFUTP regulations, holding the appellants' contentions on board authorisation and alleged bona fides to be unavailing and the impugned order free of legal infirmity.
The AT dismissed the appeals and upheld the regulatory order finding fraudulent issuance of GDRs to create a false impression of USD 24.25 million foreign subscription. The tribunal concluded the first appellant and the company materially altered and acquiesced to a pledge agreement with a foreign bank, evidencing control over funds and subsequent interest remittal, notwithstanding absence of genuine receipt of subscription monies. The AT affirmed restraint from securities market access for three years and imposition of monetary penalties for contraventions of statutory provisions and PFUTP regulations, holding the appellants' contentions on board authorisation and alleged bona fides to be unavailing and the impugned order free of legal infirmity.
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