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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AT held that allegations that the appellant filed a false FIR, obtained clients' trading account details and executed trades on their behalf with improper risk profiling, and accepted cash payments were proved. The appellant's failure to inform the Board under Regulation 13(b) of the material change was thereby established in relation to the false FIR. The AT found the appellant liable under Section 15HA only and, having considered the facts and admissions, reduced the quantum of monetary penalty as sufficient to meet the ends of justice, without imposing additional statutory penalties.
AT held that allegations that the appellant filed a false FIR, obtained clients' trading account details and executed trades on their behalf with improper risk profiling, and accepted cash payments were proved. The appellant's failure to inform the Board under Regulation 13(b) of the material change was thereby established in relation to the false FIR. The AT found the appellant liable under Section 15HA only and, having considered the facts and admissions, reduced the quantum of monetary penalty as sufficient to meet the ends of justice, without imposing additional statutory penalties.
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