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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Customs adjudication in gold smuggling matters turns on the proved seizure, corroboration and nexus, not on untested allegations of a larger conspiracy. The Tribunal treated retracted statements under Section 108 as usable only where supported by independent material such as call data, travel records, recoveries, money trails and other surrounding circumstances, and it held that cross-examination is not an absolute right in quasi-judicial proceedings. Where the department proved a nexus, penalties and confiscation were sustained or reduced; where corroboration was absent, penalties and related confiscations were set aside.
Customs adjudication in gold smuggling matters turns on the proved seizure, corroboration and nexus, not on untested allegations of a larger conspiracy. The Tribunal treated retracted statements under Section 108 as usable only where supported by independent material such as call data, travel records, recoveries, money trails and other surrounding circumstances, and it held that cross-examination is not an absolute right in quasi-judicial proceedings. Where the department proved a nexus, penalties and confiscation were sustained or reduced; where corroboration was absent, penalties and related confiscations were set aside.
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