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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The case involved a Stay petition u/s Order-in-Appeal setting aside a fine for late filing of Bill of Entry. Appellant faced technical glitches while filing through ICEGATE, leading to automatic imposition of fine. Despite efforts to file on time, technical issues prevented timely submission. Commissioner (Appeals) considered documentary evidence and relied on precedent (M/S. BLUELEAF TRADING COMPANY case) to conclude no mala fide intent. The Tribunal found no reason to interfere with the Commissioner's decision, dismissing the Revenue's appeal.
The case involved a Stay petition u/s Order-in-Appeal setting aside a fine for late filing of Bill of Entry. Appellant faced technical glitches while filing through ICEGATE, leading to automatic imposition of fine. Despite efforts to file on time, technical issues prevented timely submission. Commissioner (Appeals) considered documentary evidence and relied on precedent (M/S. BLUELEAF TRADING COMPANY case) to conclude no mala fide intent. The Tribunal found no reason to interfere with the Commissioner's decision, dismissing the Revenue's appeal.
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