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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Refund Of excess amount of duty paid on short shipped quantity - Valuation - erroneous calculation of FOB value of the subject consignment - The Appellate Tribunal found in favor of the appellant, ruling that the assessment of customs duty was incorrect as it was based on the wrong basis, resulting in excess duty payment. The Tribunal also noted the appellant's entitlement to a refund for both the short shipment and the erroneous calculation of FOB value. Moreover, the Tribunal emphasized the importance of adhering to principles of natural justice in adjudicating such matters and considered legal precedents supporting the appellant's position.
Refund Of excess amount of duty paid on short shipped quantity - Valuation - erroneous calculation of FOB value of the subject consignment - The Appellate Tribunal found in favor of the appellant, ruling that the assessment of customs duty was incorrect as it was based on the wrong basis, resulting in excess duty payment. The Tribunal also noted the appellant's entitlement to a refund for both the short shipment and the erroneous calculation of FOB value. Moreover, the Tribunal emphasized the importance of adhering to principles of natural justice in adjudicating such matters and considered legal precedents supporting the appellant's position.
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