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 over the appealability of assessments and the refund of excess customs duty payment. The appellate tribunal held that the refund claim was rejected as it was not part of the final reassessment order. The appellant should have challenged the final reassessment order to modify the amount. Refund proceedings cannot alter assessments unless modified. All assessments, including self-assessments, are appealable. The appellant's claim for refund was rightly rejected, citing the principle of unjust enrichment. The appeal was dismissed as there were no merits.
The case involved a dispute over the appealability of assessments and the refund of excess customs duty payment. The appellate tribunal held that the refund claim was rejected as it was not part of the final reassessment order. The appellant should have challenged the final reassessment order to modify the amount. Refund proceedings cannot alter assessments unless modified. All assessments, including self-assessments, are appealable. The appellant's claim for refund was rightly rejected, citing the principle of unjust enrichment. The appeal was dismissed as there were no merits.
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