Authentication of paper assessment orders upheld, while qualifying repairs, consumables and vendor advance write-offs remain deductible business claim...
Transaction value cannot be rejected solely on non-statutory valuation guidelines without corroborative evidence supporting reassessment of final cust...
Cross-examination rights and corroborated evidence limit customs penalties for misdeclaration in genuine import transactions involving documented clea...
Tariff classification of vehicle gear components follows the specific gearing entry, displacing motor-vehicle parts classification and related liabili...
Necessary-party requirements limit impleadment of independent entities, while deferred consideration does not create an appealable adverse determinati...
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Pure cost-to-cost reimbursements for IT infrastructure and software support, seconded employee salaries, and travel costs were treated as non-income items, not fees for technical, managerial, or consultancy services, so no withholding obligation arose and the related disallowances were deleted. On receivables, the text states that where the advance pricing agreement did not fix a specific date for applying prevailing LIBOR, the assessee's use of publicly available six-month USD LIBOR was accepted and the transfer pricing adjustment for delayed realisation of invoices was set aside.
Pure cost-to-cost reimbursements for IT infrastructure and software support, seconded employee salaries, and travel costs were treated as non-income items, not fees for technical, managerial, or consultancy services, so no withholding obligation arose and the related disallowances were deleted. On receivables, the text states that where the advance pricing agreement did not fix a specific date for applying prevailing LIBOR, the assessee's use of publicly available six-month USD LIBOR was accepted and the transfer pricing adjustment for delayed realisation of invoices was set aside.
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