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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Section 108 statements were held admissible as substantive evidence to connect an implicated person with customs contraventions, and consistent recorded statements, corroborated by collateral material including forensic analysis of a detained mobile phone and other witness statements, furnished adequate material to sustain confiscation and penalties. The court accepted that the petitioner's communications, non-cooperation with summons and implicated statements of a money exchanger established knowledge and participation in improper export; differing relief granted to a passenger (redemption and re-export) did not warrant parity-based relief under equality principles. The petition was dismissed and impugned orders upheld.
Section 108 statements were held admissible as substantive evidence to connect an implicated person with customs contraventions, and consistent recorded statements, corroborated by collateral material including forensic analysis of a detained mobile phone and other witness statements, furnished adequate material to sustain confiscation and penalties. The court accepted that the petitioner's communications, non-cooperation with summons and implicated statements of a money exchanger established knowledge and participation in improper export; differing relief granted to a passenger (redemption and re-export) did not warrant parity-based relief under equality principles. The petition was dismissed and impugned orders upheld.
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