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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Advance licence - advance licence had been obtained by misrepresentation or not - importing a different material than one permitted under the licence - violation of the conditions of licence or mis-utilization of the licence - The tribunal on the basis of meticulous appreciation of evidence on record has held that the respondent has not violated the conditions of exemption Notification and has discharged its export obligations. It has further been held that there has been no violation of actual user condition. - Order of tribunal confirmed - HC
Advance licence - advance licence had been obtained by misrepresentation or not - importing a different material than one permitted under the licence - violation of the conditions of licence or mis-utilization of the licence - The tribunal on the basis of meticulous appreciation of evidence on record has held that the respondent has not violated the conditions of exemption Notification and has discharged its export obligations. It has further been held that there has been no violation of actual user condition. - Order of tribunal confirmed - HC
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