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...
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Concurrent factual findings established that the appellant had transferred title to the imported goods and was not their owner. The goods were consigned to fictitious importing firms lacking importer-exporter codes and were routed without proper banking channels, supporting findings of systematic fraud and illegal importation. These factual findings warranted confiscation and penalty and did not raise a substantial question of law. Confiscation, refusal of re-shipment and penalty were sustained, and the customs appeal was dismissed.
Concurrent factual findings established that the appellant had transferred title to the imported goods and was not their owner. The goods were consigned to fictitious importing firms lacking importer-exporter codes and were routed without proper banking channels, supporting findings of systematic fraud and illegal importation. These factual findings warranted confiscation and penalty and did not raise a substantial question of law. Confiscation, refusal of re-shipment and penalty were sustained, and the customs appeal was dismissed.
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