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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Undervaluation of imported goods - The existence of the emails/ documents at the time of import is very much doubtful. It is pertinent to note that it is not the case of the department that such evidences were recovered in course of search. The records indicate that the same are produced by the appellants. - Department has not relied upon any other important documentary evidences or any contemporaneous import - Demand set aside.
Undervaluation of imported goods - The existence of the emails/ documents at the time of import is very much doubtful. It is pertinent to note that it is not the case of the department that such evidences were recovered in course of search. The records indicate that the same are produced by the appellants. - Department has not relied upon any other important documentary evidences or any contemporaneous import - Demand set aside.
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