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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Black sand produced during the manufacturing process of castings was held to be a non-dutiable good, not a manufactured product. The tribunal ruled that even if the appellant intended to manufacture black sand using natural sand, which itself is non-dutiable, when the natural sand turns black during the casting process, it does not lose its character. Apart from the color change, no material differences were established. The authorities erred in imposing duty liability on the black sand, which was not manufactured. The impugned order was set aside, and the appeal was allowed.
Black sand produced during the manufacturing process of castings was held to be a non-dutiable good, not a manufactured product. The tribunal ruled that even if the appellant intended to manufacture black sand using natural sand, which itself is non-dutiable, when the natural sand turns black during the casting process, it does not lose its character. Apart from the color change, no material differences were established. The authorities erred in imposing duty liability on the black sand, which was not manufactured. The impugned order was set aside, and the appeal was allowed.
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