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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Seeking amendment in the shipping bills - Period of limitation - The Tribunal deemed the 2010 CBEC circular invalid, citing judgments by the Gujarat High Court and the High Court of Bombay. These judgments declared the circular ultra vires and directed authorities to reconsider amendment applications without imposing time limits. Consequently, the Tribunal set aside the communication denying the appellant's request and instructed reconsideration by the Commissioner of Customs within a specified time frame, ensuring a personal hearing for the appellant.
Seeking amendment in the shipping bills - Period of limitation - The Tribunal deemed the 2010 CBEC circular invalid, citing judgments by the Gujarat High Court and the High Court of Bombay. These judgments declared the circular ultra vires and directed authorities to reconsider amendment applications without imposing time limits. Consequently, the Tribunal set aside the communication denying the appellant's request and instructed reconsideration by the Commissioner of Customs within a specified time frame, ensuring a personal hearing for the appellant.
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