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 re-export of goods - Absolute confiscation of goods - breach of ‘intellectual property rights’ - The tribunal found that while the goods were correctly confiscated under sections 111(d), 111(f), 111(l), and 111(m) of the Customs Act, 1962, the option for re-export should have been given for goods that were importable under specific conditions. - It was determined that while the goods were rightly confiscated due to violations of import regulations, the method of handling the aftermath, including the destruction of goods and some of the penalty assessments, was inappropriate and exceeded legal authority.
Seeking re-export of goods - Absolute confiscation of goods - breach of ‘intellectual property rights’ - The tribunal found that while the goods were correctly confiscated under sections 111(d), 111(f), 111(l), and 111(m) of the Customs Act, 1962, the option for re-export should have been given for goods that were importable under specific conditions. - It was determined that while the goods were rightly confiscated due to violations of import regulations, the method of handling the aftermath, including the destruction of goods and some of the penalty assessments, was inappropriate and exceeded legal authority.
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