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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Seeking release of goods for re-export - import of Dried Areca Nuts Split and Black Pepper for the purpose of re-export - Insofar as the goods which are not subject matter of investigation and/or which are otherwise not the subject matter of the Bills of Entry as set out in paragraph 23 of the reply filed on behalf of the Respondents, the same cannot be kept detained. The Respondents need to take an appropriate decision in that regard as expeditiously as possible - HC
Seeking release of goods for re-export - import of Dried Areca Nuts Split and Black Pepper for the purpose of re-export - Insofar as the goods which are not subject matter of investigation and/or which are otherwise not the subject matter of the Bills of Entry as set out in paragraph 23 of the reply filed on behalf of the Respondents, the same cannot be kept detained. The Respondents need to take an appropriate decision in that regard as expeditiously as possible - HC
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