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 of goods and redemption fine - Exemption under Advance Authorization Scheme - Demand of IGST with interest paid on import of copper concentrate before the finalization of the provisional assessment of the bill of entry - The Tribunal found that there was no mala fide intention on the part of the appellant, and the entire process occurred under the supervision of Customs Authorities. The Tribunal also held that confiscation of goods and imposition of redemption fine were not sustainable as there was no seizure or provisional release of goods.
Confiscation of goods and redemption fine - Exemption under Advance Authorization Scheme - Demand of IGST with interest paid on import of copper concentrate before the finalization of the provisional assessment of the bill of entry - The Tribunal found that there was no mala fide intention on the part of the appellant, and the entire process occurred under the supervision of Customs Authorities. The Tribunal also held that confiscation of goods and imposition of redemption fine were not sustainable as there was no seizure or provisional release of goods.
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