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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Suspension of a Container Freight Station approval was remanded for fresh consideration because the Tribunal had not been asked to decide the specific contention that suspension under Regulation 11(2) of the Handling of Cargo in Customs Areas Regulations, 2009 is only preventive and cannot continue once the required material is supplied. As that point had not been urged below, the Tribunal had recorded no finding on it. By consent, the impugned order was set aside, all merits were kept open, the suspension order stood revived pending the restored appeal, and the matter was directed to be heard by a different Bench.
Suspension of a Container Freight Station approval was remanded for fresh consideration because the Tribunal had not been asked to decide the specific contention that suspension under Regulation 11(2) of the Handling of Cargo in Customs Areas Regulations, 2009 is only preventive and cannot continue once the required material is supplied. As that point had not been urged below, the Tribunal had recorded no finding on it. By consent, the impugned order was set aside, all merits were kept open, the suspension order stood revived pending the restored appeal, and the matter was directed to be heard by a different Bench.
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