Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
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Imported aluminium formwork panels were treated as movable shuttering and support used for in situ pouring of concrete, not as moulds producing identifiable articles. On that basis, the text states that classification under CTH 84806000 was unsustainable, while CTH 76109010 for aluminium structures was accepted by reference to HSN explanatory notes. It also notes that demand enhancement based on a certificate of origin defect could not be sustained because that objection was not raised in the show cause notice, and the adjudicating authority had gone beyond its scope.
Imported aluminium formwork panels were treated as movable shuttering and support used for in situ pouring of concrete, not as moulds producing identifiable articles. On that basis, the text states that classification under CTH 84806000 was unsustainable, while CTH 76109010 for aluminium structures was accepted by reference to HSN explanatory notes. It also notes that demand enhancement based on a certificate of origin defect could not be sustained because that objection was not raised in the show cause notice, and the adjudicating authority had gone beyond its scope.
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