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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Proportionality of an administrative penalty was contested following prolonged disciplinary proceedings that triggered an automatic suspension of authorisation. The reasoning emphasises that excessive delay between showcause notice and final order produced cumulative prejudice, making the original twoyear suspension disproportionate. The disciplinary committee failed to account for the period already endured; consequently, the active suspension was reduced to time already served and deemed ended from the date of the order. The decision therefore mitigates penalty based on delay, cumulative effect, and failure to consider mitigating factors.
Proportionality of an administrative penalty was contested following prolonged disciplinary proceedings that triggered an automatic suspension of authorisation. The reasoning emphasises that excessive delay between showcause notice and final order produced cumulative prejudice, making the original twoyear suspension disproportionate. The disciplinary committee failed to account for the period already endured; consequently, the active suspension was reduced to time already served and deemed ended from the date of the order. The decision therefore mitigates penalty based on delay, cumulative effect, and failure to consider mitigating factors.
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