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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Provisional release of goods - Classification of imported goods - Heavy Melting Scrap ISRI Code 200 to 206 - goods were found to be “old and used CRGO (secondary Cold Rolled Grain Oriented) Sheets/old and used “empty gas cylinder” and “Table Tennis Rackets” - prohibited goods or not - When similar import declared as HMS and reclassified and reassessed as CRGO sheets were ordered to be released after mutilation and payment of duty, there are no reason to interfere with the view taken by the Commissioner (Appeals) directing provisional release of the impugned goods. - AT
Provisional release of goods - Classification of imported goods - Heavy Melting Scrap ISRI Code 200 to 206 - goods were found to be “old and used CRGO (secondary Cold Rolled Grain Oriented) Sheets/old and used “empty gas cylinder” and “Table Tennis Rackets” - prohibited goods or not - When similar import declared as HMS and reclassified and reassessed as CRGO sheets were ordered to be released after mutilation and payment of duty, there are no reason to interfere with the view taken by the Commissioner (Appeals) directing provisional release of the impugned goods. - AT
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