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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Receipt of foreign currency through a non-banking channel was admitted to have accrued on 16.07.2007 and not repatriated/surrendered within 180 days, constituting contravention of Section 3(a) and Section 4 of the Act of 1999 and Section 8 read with Regulations 3 and 7 of the 2000 Regulations; the penalty was therefore sustained but reduced proportionately considering the amount involved in Singapore Dollars, with adjustment of any pre-deposit. Separately, confiscation of the seized cash was set aside because there was no finding that the cash was used or involved in any hawala transaction or other contravention, and mere possession without nexus to a violation did not justify confiscation. - AT
Receipt of foreign currency through a non-banking channel was admitted to have accrued on 16.07.2007 and not repatriated/surrendered within 180 days, constituting contravention of Section 3(a) and Section 4 of the Act of 1999 and Section 8 read with Regulations 3 and 7 of the 2000 Regulations; the penalty was therefore sustained but reduced proportionately considering the amount involved in Singapore Dollars, with adjustment of any pre-deposit. Separately, confiscation of the seized cash was set aside because there was no finding that the cash was used or involved in any hawala transaction or other contravention, and mere possession without nexus to a violation did not justify confiscation. - AT
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