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...
Page of 4827
Press 'Enter' after typing page number.
161 to 180 of 96536 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
AT upheld the admissibility and evidentiary value of statements recorded u/s 40 FERA, despite subsequent retraction, holding that retraction alone does not establish involuntariness and noting sufficient independent and cogent corroborative evidence, including recovered documents, seized cash and corroborating statements. AT affirmed findings of contravention of Ss. 8(1), 8(2), 9(1)(f)(i) and 14 FERA, rejecting the appellant's challenge to the merits of the adjudication. However, considering the appellant's age and prior deposit of part of the penalty, AT exercised discretion to reduce the penalty to Rs. 9,00,000/-, directing adjustment of amounts already deposited/released. Appeal was thus partly allowed, limited to quantum of penalty.
AT upheld the admissibility and evidentiary value of statements recorded u/s 40 FERA, despite subsequent retraction, holding that retraction alone does not establish involuntariness and noting sufficient independent and cogent corroborative evidence, including recovered documents, seized cash and corroborating statements. AT affirmed findings of contravention of Ss. 8(1), 8(2), 9(1)(f)(i) and 14 FERA, rejecting the appellant's challenge to the merits of the adjudication. However, considering the appellant's age and prior deposit of part of the penalty, AT exercised discretion to reduce the penalty to Rs. 9,00,000/-, directing adjustment of amounts already deposited/released. Appeal was thus partly allowed, limited to quantum of penalty.
Note: It is a system-generated summary and is for quick reference only.