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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Eligibility of petitioner in seeking clearance of the goods - High Seas Sale agreement stands cancelled - The petitioner contested the jurisdiction of the authorities, sought to quash an impugned letter, and requested the release of containers and amendment of the Bill of Entry. Additionally, the petitioner challenged the validity of a CBIC notification and requested detention and demurrage waivers. The High court acknowledged the petitioner's entitlement to seek clearance due to the cancellation of a High Seas Sale agreement and permitted the submission of an application to the designated Customs Officer. Respondent No. 6 raised no objections, and the court directed a timely decision on the application, while keeping all contentions open.
Eligibility of petitioner in seeking clearance of the goods - High Seas Sale agreement stands cancelled - The petitioner contested the jurisdiction of the authorities, sought to quash an impugned letter, and requested the release of containers and amendment of the Bill of Entry. Additionally, the petitioner challenged the validity of a CBIC notification and requested detention and demurrage waivers. The High court acknowledged the petitioner's entitlement to seek clearance due to the cancellation of a High Seas Sale agreement and permitted the submission of an application to the designated Customs Officer. Respondent No. 6 raised no objections, and the court directed a timely decision on the application, while keeping all contentions open.
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