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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Prayer for a Mandamus to release the consignment of Betel nut imported - prohibited goods or not - Customs department challenging the order of Customs Authority for Advance Ruling - High Court observed that, the clarification or ruling given by the Authority for Advance Rulings (AAR) is binding unless changed by law or annulled under Section 28-K of the Customs Act. - The classification of imported goods is a factual determination to be made by the Assessing Officer considering physical and chemical examination and the commercial parlance test. - Imported goods can be provisionally released under Section 110 of the Customs Act, subject to payment of customs duty on the tariff value, without the need for absolute confiscation.
Prayer for a Mandamus to release the consignment of Betel nut imported - prohibited goods or not - Customs department challenging the order of Customs Authority for Advance Ruling - High Court observed that, the clarification or ruling given by the Authority for Advance Rulings (AAR) is binding unless changed by law or annulled under Section 28-K of the Customs Act. - The classification of imported goods is a factual determination to be made by the Assessing Officer considering physical and chemical examination and the commercial parlance test. - Imported goods can be provisionally released under Section 110 of the Customs Act, subject to payment of customs duty on the tariff value, without the need for absolute confiscation.
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