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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Process amounting to manufacture or not - Process of separating foot oil, pressed wax, and paraffin wax from slack wax and residue wax - tilting, separating and pressing with hydraulic press - The Tribunal analyzed the process undertaken by the respondent, involving manual turning of drums, pouring contents onto gunny cloth for natural pressure, and using a hydraulic press for expediting the straining process. They observed that no machinery was used for separation, and the process did not result in new products. - They noted that the separated products retained the same characteristics as the original wax, as per technical literature and legal precedents. Therefore, the Tribunal held that the activities did not meet the definition of "manufacture" under the Central Excise Act, 1944.
Process amounting to manufacture or not - Process of separating foot oil, pressed wax, and paraffin wax from slack wax and residue wax - tilting, separating and pressing with hydraulic press - The Tribunal analyzed the process undertaken by the respondent, involving manual turning of drums, pouring contents onto gunny cloth for natural pressure, and using a hydraulic press for expediting the straining process. They observed that no machinery was used for separation, and the process did not result in new products. - They noted that the separated products retained the same characteristics as the original wax, as per technical literature and legal precedents. Therefore, the Tribunal held that the activities did not meet the definition of "manufacture" under the Central Excise Act, 1944.
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