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 the appellant firm contravened s.10(6) FEMA read with para 6(1) of the 2000 Regulations by remitting foreign exchange abroad against empty containers without due diligence and by failing to take serious legal steps to recover the remittance. The firm's plea of having been cheated was accepted only to the extent of mitigating penalty, which was reduced to 25% of that imposed in the impugned order, with FDR pre-deposit, if encashable, to be adjusted towards the reduced penalty. Penalty against the deceased individual appellant, represented through legal representative, was set aside. The firm's appeal was partly allowed; the individual's appeal was allowed.
AT held the appellant firm contravened s.10(6) FEMA read with para 6(1) of the 2000 Regulations by remitting foreign exchange abroad against empty containers without due diligence and by failing to take serious legal steps to recover the remittance. The firm's plea of having been cheated was accepted only to the extent of mitigating penalty, which was reduced to 25% of that imposed in the impugned order, with FDR pre-deposit, if encashable, to be adjusted towards the reduced penalty. Penalty against the deceased individual appellant, represented through legal representative, was set aside. The firm's appeal was partly allowed; the individual's appeal was allowed.
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