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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Scope of supply - transfer of title of goods by the Applicant to its customers or multiple transfers within the FTWZ - The AAAR finds that the AAR failed to address the appellant's question comprehensively, as it only discussed para 8(a) of Schedule III and did not consider para 8(b) or other relevant entries. Hence, the matter is remanded to the lower authority for a fresh examination. - The AAAR notes that the AAR did not thoroughly examine whether FTWZ should be considered as a customs bonded warehouse. Therefore, it directs the lower authority to consider this aspect along with other contentions raised by the appellant.
Scope of supply - transfer of title of goods by the Applicant to its customers or multiple transfers within the FTWZ - The AAAR finds that the AAR failed to address the appellant's question comprehensively, as it only discussed para 8(a) of Schedule III and did not consider para 8(b) or other relevant entries. Hence, the matter is remanded to the lower authority for a fresh examination. - The AAAR notes that the AAR did not thoroughly examine whether FTWZ should be considered as a customs bonded warehouse. Therefore, it directs the lower authority to consider this aspect along with other contentions raised by the appellant.
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