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 involves the Appellant challenging the enhancement of declared values for clearances to the DTA Unit by the specified officer, MEPZ-SEZ. The Appellant's declared values were accepted as transaction value under Customs Valuation Rules, 2007 until July 2018. The issue arose when the values were enhanced without proper communication or justification, leading to a violation of natural justice. The Appellate Tribunal set aside the lower authority's order, citing a lack of discussion on the violation of principles of natural justice. The case was remanded for a well-reasoned determination of values in accordance with the Customs Act, 1962. The appeal was allowed by way of remand.
The case involves the Appellant challenging the enhancement of declared values for clearances to the DTA Unit by the specified officer, MEPZ-SEZ. The Appellant's declared values were accepted as transaction value under Customs Valuation Rules, 2007 until July 2018. The issue arose when the values were enhanced without proper communication or justification, leading to a violation of natural justice. The Appellate Tribunal set aside the lower authority's order, citing a lack of discussion on the violation of principles of natural justice. The case was remanded for a well-reasoned determination of values in accordance with the Customs Act, 1962. The appeal was allowed by way of remand.
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