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 held that the show-cause notice seeking revocation of the customs broker licence and penalty was jurisdictionally defective because it did not state the date of receipt of the offence report as mandated by Regulation 20(1) of the CBLR 2013, a time limit treated as mandatory. Consequently, proceedings and consequential adverse findings premised on that notice are quashed to the extent they resulted in forfeiture of the broker's security deposit. The Tribunal declined to examine merits in view of the jurisdictional infirmity, set aside the impugned forfeiture order insofar as it affected the anonymized customs broker, and dismissed the appeal preferred by the Revenue.
CESTAT held that the show-cause notice seeking revocation of the customs broker licence and penalty was jurisdictionally defective because it did not state the date of receipt of the offence report as mandated by Regulation 20(1) of the CBLR 2013, a time limit treated as mandatory. Consequently, proceedings and consequential adverse findings premised on that notice are quashed to the extent they resulted in forfeiture of the broker's security deposit. The Tribunal declined to examine merits in view of the jurisdictional infirmity, set aside the impugned forfeiture order insofar as it affected the anonymized customs broker, and dismissed the appeal preferred by the Revenue.
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