Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
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Related-party customs valuation was re-opened because later investigation disclosed fresh agreements, merger-related changes and different valuation methodologies, so earlier SVB and Tribunal orders did not bar reconsideration. The declared transaction value was rejected as not reflecting an uninfluenced price; valuation was directed on the deductive method where list price existed and on the computed method where it did not, with a 38% trade discount, admissible general expenses, and no separate addition for freight or insurance. Exemption under Notification No. 89/1982-Cus. was denied for SAD under strict construction, the extended limitation period was upheld for suppression, confiscation on an unnotified ground was set aside, and interest and penalty survived only for the BCD component.
Related-party customs valuation was re-opened because later investigation disclosed fresh agreements, merger-related changes and different valuation methodologies, so earlier SVB and Tribunal orders did not bar reconsideration. The declared transaction value was rejected as not reflecting an uninfluenced price; valuation was directed on the deductive method where list price existed and on the computed method where it did not, with a 38% trade discount, admissible general expenses, and no separate addition for freight or insurance. Exemption under Notification No. 89/1982-Cus. was denied for SAD under strict construction, the extended limitation period was upheld for suppression, confiscation on an unnotified ground was set aside, and interest and penalty survived only for the BCD component.
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