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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Penalty on a customs broker was not justified where employees independently took clients and filed Bills of Entry without the broker's knowledge, approval, or authorisation. The Tribunal found no evidence that the broker had any active role in the prohibited acts, and noted that the employees had admitted acting without the Managing Director's consent. It also considered the broker's action against the erring employees. In the absence of material showing knowledge, authorisation, or involvement, the penalty imposed under the relevant customs broker regulation was set aside.
Penalty on a customs broker was not justified where employees independently took clients and filed Bills of Entry without the broker's knowledge, approval, or authorisation. The Tribunal found no evidence that the broker had any active role in the prohibited acts, and noted that the employees had admitted acting without the Managing Director's consent. It also considered the broker's action against the erring employees. In the absence of material showing knowledge, authorisation, or involvement, the penalty imposed under the relevant customs broker regulation was set aside.
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