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 pertains to the classification of imported Artemia Cysts (Brine Shrimp Eggs) under the Customs Tariff Heading (CTH). The Tribunal held that prior to the eight-digit classification introduced in 2003, the product would fall under CTH 0511.99, and even after the modification, it was specifically brought under 0511.99.11. Considering the Chapter Notes and descriptions, it was concluded that the goods should be classified under CTH 0511.99 during the disputed period. The penalties imposed on the appellant company u/s 114A and on an individual u/s 112(a) of the Customs Act were set aside. The appeal was allowed in part.
The case pertains to the classification of imported Artemia Cysts (Brine Shrimp Eggs) under the Customs Tariff Heading (CTH). The Tribunal held that prior to the eight-digit classification introduced in 2003, the product would fall under CTH 0511.99, and even after the modification, it was specifically brought under 0511.99.11. Considering the Chapter Notes and descriptions, it was concluded that the goods should be classified under CTH 0511.99 during the disputed period. The penalties imposed on the appellant company u/s 114A and on an individual u/s 112(a) of the Customs Act were set aside. The appeal was allowed in part.
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