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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100% EOUs - delay in fulfilment of export obligations - Customs Warehousing Licence for warehousing, manufacturing and export of software - Upon review, the Tribunal found that the appellant applied for an extension, which was ultimately granted by the Development Commissioner with retrospective effect, providing an additional five years to fulfill export obligations starting from May 2008. Critically, the Tribunal concluded that the impugned order was premature, as it was passed before the final decision on the extension request. Given the retrospective approval, the demands raised in the order were deemed unsustainable.
100% EOUs - delay in fulfilment of export obligations - Customs Warehousing Licence for warehousing, manufacturing and export of software - Upon review, the Tribunal found that the appellant applied for an extension, which was ultimately granted by the Development Commissioner with retrospective effect, providing an additional five years to fulfill export obligations starting from May 2008. Critically, the Tribunal concluded that the impugned order was premature, as it was passed before the final decision on the extension request. Given the retrospective approval, the demands raised in the order were deemed unsustainable.
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