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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The appellants alleged breach of natural justice due to non-supply of relied-upon documents and lack of effective hearing, but the record showed all seized and relied documents were supplied under acknowledgment and notices were ignored, indicating deliberate non-cooperation; the adjudication was therefore sustained. Confiscation of seized Indian currency was upheld as the appellants failed to explain its source. Separate penalties for contraventions of ss. 3(a), 3(b), 3(d) and 4 were held permissible under s. 13(1)-(2), but the cumulative penalty on each appellant was reduced in the interest of justice, with prior pre-deposit adjusted against the reduced penalty. - AT
The appellants alleged breach of natural justice due to non-supply of relied-upon documents and lack of effective hearing, but the record showed all seized and relied documents were supplied under acknowledgment and notices were ignored, indicating deliberate non-cooperation; the adjudication was therefore sustained. Confiscation of seized Indian currency was upheld as the appellants failed to explain its source. Separate penalties for contraventions of ss. 3(a), 3(b), 3(d) and 4 were held permissible under s. 13(1)-(2), but the cumulative penalty on each appellant was reduced in the interest of justice, with prior pre-deposit adjusted against the reduced penalty. - AT
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