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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Petitioner can bring gold chain with diamond pendant into India as personal effect under Baggage Rules 1998. Invoice for diamond purchase though unsigned, cannot be sole basis for rejection. Personal effect interpretation depends on context and person's background. For high net worth individual like Petitioner engaged in jewelry business with declared income of USD 150,000, expensive jewelry qualifies as personal effect. Customs authorities erred in initiating proceedings merely on high value ascription without considering Petitioner's background and valuation date discrepancy. Respondents directed to refund Rs. 35,00,000 deposited by Petitioner within four weeks.
Petitioner can bring gold chain with diamond pendant into India as personal effect under Baggage Rules 1998. Invoice for diamond purchase though unsigned, cannot be sole basis for rejection. Personal effect interpretation depends on context and person's background. For high net worth individual like Petitioner engaged in jewelry business with declared income of USD 150,000, expensive jewelry qualifies as personal effect. Customs authorities erred in initiating proceedings merely on high value ascription without considering Petitioner's background and valuation date discrepancy. Respondents directed to refund Rs. 35,00,000 deposited by Petitioner within four weeks.
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