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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Imports of mineral hydrocarbon oil in drums, and the related classification dispute under heading 27101990 versus 2710 1290, were treated as covered by the Tribunal's earlier decision in the importers' own case. On that footing, the Tribunal stated that no redemption fine and no penalty were imposable for the alleged contravention of the Petroleum Rules, 2002 and the Customs Act, 1962. The confiscation-related consequences were therefore not sustained, the impugned order was set aside, and consequential relief followed.
Imports of mineral hydrocarbon oil in drums, and the related classification dispute under heading 27101990 versus 2710 1290, were treated as covered by the Tribunal's earlier decision in the importers' own case. On that footing, the Tribunal stated that no redemption fine and no penalty were imposable for the alleged contravention of the Petroleum Rules, 2002 and the Customs Act, 1962. The confiscation-related consequences were therefore not sustained, the impugned order was set aside, and consequential relief followed.
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