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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Import of helicopter - non-scheduled air transport services (passenger) - Misuse of helicopter - Though the assessee complied with clause (i) of the Condition No. 104 ibid, they violated the post-importation condition viz. Clause (ii) of the said Condition No. 104. They also violated similar condition of Notification No. 6/06-C.E., dated 1-3-2006 (entry No. 54A) as amended by Notification No. 6/07-C.E., dated 1-3-2007 - Demand of duty and penalty confirmed..... - AT
Import of helicopter - non-scheduled air transport services (passenger) - Misuse of helicopter - Though the assessee complied with clause (i) of the Condition No. 104 ibid, they violated the post-importation condition viz. Clause (ii) of the said Condition No. 104. They also violated similar condition of Notification No. 6/06-C.E., dated 1-3-2006 (entry No. 54A) as amended by Notification No. 6/07-C.E., dated 1-3-2007 - Demand of duty and penalty confirmed..... - AT
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