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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Contraventions under the Foreign Exchange Regulation Act were established by seized office documents, export papers, bank enquiries and corroborative witness statements which explained the modus operandi of over invoicing and unauthorised conversion or transfer of Indian currency to persons outside India; the appellant produced no evidence to rebut the seizures and statements, so the violation finding was upheld. The adjudicatory delay was treated as a mitigating factor and, exercising discretion to mitigate penalty for delay, the monetary sanction was reduced to fifty thousand rupees while the finding of contravention remains affirmed.
Contraventions under the Foreign Exchange Regulation Act were established by seized office documents, export papers, bank enquiries and corroborative witness statements which explained the modus operandi of over invoicing and unauthorised conversion or transfer of Indian currency to persons outside India; the appellant produced no evidence to rebut the seizures and statements, so the violation finding was upheld. The adjudicatory delay was treated as a mitigating factor and, exercising discretion to mitigate penalty for delay, the monetary sanction was reduced to fifty thousand rupees while the finding of contravention remains affirmed.
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