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 upheld the revocation of the appellant's Customs Broker licence, forfeiture of security deposit and imposition of Rs. 50,000 penalty under CBLR. The Tribunal found that the appellant had effectively sub-let its licence for monetary consideration by allowing multiple persons to use it and by filing benami shipping bills at the behest of an intermediary, without engagement or authorization from the declared exporter. This conduct constituted violations of Regulations 1(4), 10(a), 10(d) and 10(n), though the alleged breach of Regulation 10(e) was set aside. Holding such conduct a grave risk to revenue and national security, CESTAT found the sanctions proportionate and dismissed the appeal.
CESTAT upheld the revocation of the appellant's Customs Broker licence, forfeiture of security deposit and imposition of Rs. 50,000 penalty under CBLR. The Tribunal found that the appellant had effectively sub-let its licence for monetary consideration by allowing multiple persons to use it and by filing benami shipping bills at the behest of an intermediary, without engagement or authorization from the declared exporter. This conduct constituted violations of Regulations 1(4), 10(a), 10(d) and 10(n), though the alleged breach of Regulation 10(e) was set aside. Holding such conduct a grave risk to revenue and national security, CESTAT found the sanctions proportionate and dismissed the appeal.
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