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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Import of Construction equipment - Violation of post-importation conditions of deployment - Benefit of N/N. 21/2002-Cus - recovery of duty - Despite non-utilization of the goods for the intended project due to contract termination and civil disturbances, the Tribunal ruled that non-utilization does not automatically invalidate eligibility. The premature seizure of goods during dispute resolution was deemed unjustified, leading the Tribunal to set aside the recovery of duty and confiscation, restoring the goods to the appellant for compliance with post-importation conditions.
Import of Construction equipment - Violation of post-importation conditions of deployment - Benefit of N/N. 21/2002-Cus - recovery of duty - Despite non-utilization of the goods for the intended project due to contract termination and civil disturbances, the Tribunal ruled that non-utilization does not automatically invalidate eligibility. The premature seizure of goods during dispute resolution was deemed unjustified, leading the Tribunal to set aside the recovery of duty and confiscation, restoring the goods to the appellant for compliance with post-importation conditions.
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