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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Confiscation - Smuggling - Gold Bullion - Gold Jewellery - The appellant has not adduced any evidence to indicate that the same were procured locally. Appellants who claim that the gold to have been legally procured have to produce documents evidencing payment of duty as well as documents evidencing their legal ownership/possession. During the course of investigation, it is recorded that gold bullion/coins/jewellery which was satisfactorily explained by the appellant was released to him by the investigating agency themselves. - AT
Confiscation - Smuggling - Gold Bullion - Gold Jewellery - The appellant has not adduced any evidence to indicate that the same were procured locally. Appellants who claim that the gold to have been legally procured have to produce documents evidencing payment of duty as well as documents evidencing their legal ownership/possession. During the course of investigation, it is recorded that gold bullion/coins/jewellery which was satisfactorily explained by the appellant was released to him by the investigating agency themselves. - AT
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