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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Valuation of export goods on which duty has to be paid - iron ores - The Tribunal determines that the transaction value specified in the contract between the appellant and the buyer should be considered for valuation purposes, rather than relying solely on the Customs Laboratory report. The Tribunal decides that certain deductions made to the transaction value, such as for moisture content and lump value, should not be allowed. It directs that the transaction value be determined without such deductions.
Valuation of export goods on which duty has to be paid - iron ores - The Tribunal determines that the transaction value specified in the contract between the appellant and the buyer should be considered for valuation purposes, rather than relying solely on the Customs Laboratory report. The Tribunal decides that certain deductions made to the transaction value, such as for moisture content and lump value, should not be allowed. It directs that the transaction value be determined without such deductions.
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