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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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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