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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Refund - even if the Department assessed the shipping bills, for the ductile iron spun pipes, attracting Notification No.66/2008-Cus, the right course of remedy would have to file appeal against the assessed copy of shipping bills immediately after receipt of the said assessed shipping bills before the Commissioner (Appeals). Non filing of the appeal against the assessment order of the shipping bills, cannot make them eligible for refund.
Refund - even if the Department assessed the shipping bills, for the ductile iron spun pipes, attracting Notification No.66/2008-Cus, the right course of remedy would have to file appeal against the assessed copy of shipping bills immediately after receipt of the said assessed shipping bills before the Commissioner (Appeals). Non filing of the appeal against the assessment order of the shipping bills, cannot make them eligible for refund.
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