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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Entitlement for benefit of exemption Notification - appellants themselves have classified their product under CTH 2711 1300 of the Customs Tariff Act. - While filing the provisional Bills of Entry, no protest was made with regard to classification of their product i.e. LPG. Therefore, at this juncture, the issue of classification cannot be raised to get the benefit of the above cited Notifications. - AT
Entitlement for benefit of exemption Notification - appellants themselves have classified their product under CTH 2711 1300 of the Customs Tariff Act. - While filing the provisional Bills of Entry, no protest was made with regard to classification of their product i.e. LPG. Therefore, at this juncture, the issue of classification cannot be raised to get the benefit of the above cited Notifications. - AT
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