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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Invocation of Extended Period of Limitation - though the department was informed as early as February 2001 took note of the ineligibility of the Notification in June 2003 by which the time limit prescribed for issuance of show cause notice for duty not paid not levied as already expired. - The department to cover up their inaction immediately after the submission of the said letter by the Appellants have taken recourse to invocation of extended period. We find that this is not legal and proper. No material evidence has been suppressed by the Appellants with intent to evade payment of applicable duty. - AT
Invocation of Extended Period of Limitation - though the department was informed as early as February 2001 took note of the ineligibility of the Notification in June 2003 by which the time limit prescribed for issuance of show cause notice for duty not paid not levied as already expired. - The department to cover up their inaction immediately after the submission of the said letter by the Appellants have taken recourse to invocation of extended period. We find that this is not legal and proper. No material evidence has been suppressed by the Appellants with intent to evade payment of applicable duty. - AT
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