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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Import of old and used Maquet Servoi ventilator machine with standard hoses and accessories - hazardous goods or not - That would require evidence of the conveyance having been beyond the territorial waters which has not been demonstrated by customs authorities. The relaxation in the office memorandum supra applies to the impugned goods. - In the absence of any finding that the declared value did not represent the transaction value, the confiscation and imposition of penalty, as also the redetermination of value, is not valid in law - AT
Import of old and used Maquet Servoi ventilator machine with standard hoses and accessories - hazardous goods or not - That would require evidence of the conveyance having been beyond the territorial waters which has not been demonstrated by customs authorities. The relaxation in the office memorandum supra applies to the impugned goods. - In the absence of any finding that the declared value did not represent the transaction value, the confiscation and imposition of penalty, as also the redetermination of value, is not valid in law - AT
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