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 Appellate Tribunal (CESTAT) considered a case involving undervaluation of imported engineering goods, specifically 9000 Nos. spares of water filters-75 GPD water pumps. The declared value was rejected, and the value was enhanced based on a DRI alert regarding undervaluation by overseas suppliers. The Tribunal found that the lower authorities did not consider vital documents obtained under RTI, including a CD detailing price workings and contemporary import data. This lack of consideration violated principles of natural justice. The case was remanded to the Adjudicating Authority for reevaluation based on the additional documents obtained, leading to the appeal being allowed through remand.
The Appellate Tribunal (CESTAT) considered a case involving undervaluation of imported engineering goods, specifically 9000 Nos. spares of water filters-75 GPD water pumps. The declared value was rejected, and the value was enhanced based on a DRI alert regarding undervaluation by overseas suppliers. The Tribunal found that the lower authorities did not consider vital documents obtained under RTI, including a CD detailing price workings and contemporary import data. This lack of consideration violated principles of natural justice. The case was remanded to the Adjudicating Authority for reevaluation based on the additional documents obtained, leading to the appeal being allowed through remand.
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