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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EPCG Scheme - fulfilment 100% export obligation - No doubt, that the EODC has been issued after much delay, however, the same was issued prior to the passing of the order-in-original passed by the Adjudicating Authority on 26.02.2016 and much before the impugned order on 19.11.2019. The fact that the EODC has been issued showing complete fulfilment of 100% Export Obligation, the Appellate Authority was required to consider the same and in the light of the various decisions of the High Court as well as of this Tribunal, ought to have granted the necessary relief. - AT
EPCG Scheme - fulfilment 100% export obligation - No doubt, that the EODC has been issued after much delay, however, the same was issued prior to the passing of the order-in-original passed by the Adjudicating Authority on 26.02.2016 and much before the impugned order on 19.11.2019. The fact that the EODC has been issued showing complete fulfilment of 100% Export Obligation, the Appellate Authority was required to consider the same and in the light of the various decisions of the High Court as well as of this Tribunal, ought to have granted the necessary relief. - AT
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