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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Levy of penalty - Regulation 12(8) of Handling Cargo in Customs Area Regulation, 2009 - it is found that the appellant have evidently issued the Public Notice as well as moved containers containing hazardous goods from ICD, Tuglakabad under the direction of the learned SDM, duly confirmed by the Hon’ble High Court in its interim order. Accordingly, it is held that the appellant have not violated any of the provisions of HCCAR, 2009 and/or of the Customs Act. - No penalty - AT
Levy of penalty - Regulation 12(8) of Handling Cargo in Customs Area Regulation, 2009 - it is found that the appellant have evidently issued the Public Notice as well as moved containers containing hazardous goods from ICD, Tuglakabad under the direction of the learned SDM, duly confirmed by the Hon’ble High Court in its interim order. Accordingly, it is held that the appellant have not violated any of the provisions of HCCAR, 2009 and/or of the Customs Act. - No penalty - AT
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