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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Confiscation of goods - Clandestine removal of bunkers - import of duty free Furnace Oil & HSD Fuel Oil under warehouse procedure - The tribunal conducted a thorough analysis of the procedural aspects related to the duty-free import, warehousing, and subsequent supply of the bunker fuel to foreign going vessels. It noted the appellants' compliance with the requisite customs procedures, including the filing of warehousing bonds and undertaking as per Section 59 of the Customs Act, 1962 - Ultimately, the tribunal found that the department failed to establish the charge of diversion with cogent evidence. It underscored that serious allegations such as clandestine removal and diversion necessitate robust proof, which was conspicuously absent in this case.
Confiscation of goods - Clandestine removal of bunkers - import of duty free Furnace Oil & HSD Fuel Oil under warehouse procedure - The tribunal conducted a thorough analysis of the procedural aspects related to the duty-free import, warehousing, and subsequent supply of the bunker fuel to foreign going vessels. It noted the appellants' compliance with the requisite customs procedures, including the filing of warehousing bonds and undertaking as per Section 59 of the Customs Act, 1962 - Ultimately, the tribunal found that the department failed to establish the charge of diversion with cogent evidence. It underscored that serious allegations such as clandestine removal and diversion necessitate robust proof, which was conspicuously absent in this case.
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