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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Manufacture of paper / paper board - Principal Process of lifting of pulp is done by hand or not - To extend the benefit of exemption notification, only the Principal Process of lifting of pulp by hand would be looked into - Therefore, the benefit of the exemption notification cannot be denied to the appellants, as the liquid with pulp fibres is pumped from the pulpier to storage tanks through pipe lines.
Manufacture of paper / paper board - Principal Process of lifting of pulp is done by hand or not - To extend the benefit of exemption notification, only the Principal Process of lifting of pulp by hand would be looked into - Therefore, the benefit of the exemption notification cannot be denied to the appellants, as the liquid with pulp fibres is pumped from the pulpier to storage tanks through pipe lines.
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