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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Clandestine removal - Invoices pink coloured [Duplicate for transporter] are found in factory, hence, it can also be inferred logically that goods were not transported out of factory against the said Invoices named as parallel Invoices in facts of this case. - There is no corroborative evidence of removal of goods twice on the same Invoice or on parallel Invoices and receiving payment twice for Invoices. It is found that except statements, there is nothing on record to establish Revenue’s case of clandestine manufacture or removal of goods from Appellant’s Factory, in the facts of this case. - AT
Clandestine removal - Invoices pink coloured [Duplicate for transporter] are found in factory, hence, it can also be inferred logically that goods were not transported out of factory against the said Invoices named as parallel Invoices in facts of this case. - There is no corroborative evidence of removal of goods twice on the same Invoice or on parallel Invoices and receiving payment twice for Invoices. It is found that except statements, there is nothing on record to establish Revenue’s case of clandestine manufacture or removal of goods from Appellant’s Factory, in the facts of this case. - AT
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