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 dispute regarding differential duty on goods with a Certificate of Origin from Zanzibar, warehoused during transit in the UAE. The Appellate Tribunal found that the importer failed to provide evidence of direct dispatch from Zanzibar. The Tribunal noted that Indian customs control should not be applied to goods in the UAE and highlighted procedural errors in the show cause notice. The failure to identify the person chargeable to duty or interest was deemed crucial, leading to the decision to set aside the order and remand the case for a fresh decision. The appeal was allowed by way of remand.
The case involved a dispute regarding differential duty on goods with a Certificate of Origin from Zanzibar, warehoused during transit in the UAE. The Appellate Tribunal found that the importer failed to provide evidence of direct dispatch from Zanzibar. The Tribunal noted that Indian customs control should not be applied to goods in the UAE and highlighted procedural errors in the show cause notice. The failure to identify the person chargeable to duty or interest was deemed crucial, leading to the decision to set aside the order and remand the case for a fresh decision. The appeal was allowed by way of remand.
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