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 the recovery of differential duty, interest, and penalties on imports of 'inshell walnuts' against exemption notification. The imports were made using transferable 'scrips' for manufacturing 'biscuits' with 'dietary fiber.' The tribunal found that the proceedings exceeded the statutory time limit, and the deferment notice was not issued by the proper officer as required by law. The tribunal also ruled that penalties imposed u/s 112 of the Customs Act were not valid due to the absence of conditions on imported goods against 'scrips.' The impugned order was set aside, and the appeal was allowed.
The case involved the recovery of differential duty, interest, and penalties on imports of 'inshell walnuts' against exemption notification. The imports were made using transferable 'scrips' for manufacturing 'biscuits' with 'dietary fiber.' The tribunal found that the proceedings exceeded the statutory time limit, and the deferment notice was not issued by the proper officer as required by law. The tribunal also ruled that penalties imposed u/s 112 of the Customs Act were not valid due to the absence of conditions on imported goods against 'scrips.' The impugned order was set aside, and the appeal was allowed.
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