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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Late fee for delayed supplementary Bills of Entry may be waived where the original Bills of Entry were filed on time and the excess cargo later found during draft survey formed part of the same consignments. The levy is not to be imposed mechanically; the proper officer may waive it for sufficient cause under the statutory scheme. Board guidelines and departmental SOP require a judicious approach, and where the importer's bona fides are not in doubt, the late fee is unwarranted.
Late fee for delayed supplementary Bills of Entry may be waived where the original Bills of Entry were filed on time and the excess cargo later found during draft survey formed part of the same consignments. The levy is not to be imposed mechanically; the proper officer may waive it for sufficient cause under the statutory scheme. Board guidelines and departmental SOP require a judicious approach, and where the importer's bona fides are not in doubt, the late fee is unwarranted.
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