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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Authenticity of the country of origin certificate - concessional rate of duty - The Tribunal observed that while the appellant produced COOs issued by the Malaysian authorities, the DRI's investigation suggested discrepancies. The Tribunal acknowledged the need for further verification of the COOs' authenticity from the Malaysian government. - Despite the DRI's findings, the Tribunal noted that the department failed to obtain verification from Malaysian authorities regarding the COOs' genuineness. Consequently, the Tribunal set aside the impugned order and allowed the appeals for a fresh adjudication.
Authenticity of the country of origin certificate - concessional rate of duty - The Tribunal observed that while the appellant produced COOs issued by the Malaysian authorities, the DRI's investigation suggested discrepancies. The Tribunal acknowledged the need for further verification of the COOs' authenticity from the Malaysian government. - Despite the DRI's findings, the Tribunal noted that the department failed to obtain verification from Malaysian authorities regarding the COOs' genuineness. Consequently, the Tribunal set aside the impugned order and allowed the appeals for a fresh adjudication.
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