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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Permitting third-party use of an Import Export Code (IEC) contrary to the Foreign Trade Act and Rules renders the imported goods liable to confiscation and attracts penalty under Section 112(a) of the Customs Act; the tribunal relied on the appellant's voluntary admission that he lent his IEC to a syndicate to support that finding and upheld the penalty. Separately, knowingly making, signing or using false or incorrect declarations satisfies the ingredients of the penalty provision for false declarations and the tribunal upheld the penalty under Section 114AA on that basis.
Permitting third-party use of an Import Export Code (IEC) contrary to the Foreign Trade Act and Rules renders the imported goods liable to confiscation and attracts penalty under Section 112(a) of the Customs Act; the tribunal relied on the appellant's voluntary admission that he lent his IEC to a syndicate to support that finding and upheld the penalty. Separately, knowingly making, signing or using false or incorrect declarations satisfies the ingredients of the penalty provision for false declarations and the tribunal upheld the penalty under Section 114AA on that basis.
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