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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Circular trading allegations of Cut and Polished Diamonds (CPD) and Gold Jewellery, over-invoicing exports of studded Gold Jewellery, misuse of Target Plus Scheme were raised. However, identical allegations were previously set aside by the Tribunal, affirmed by Supreme Court, holding no inter-relationship between parties, no circular trading. Joint DGFT order accepted no circular trading, exports valid for discharge of Advance License obligations. DGFT didn't cancel licenses or take action against respondents. Revenue's allegation of misdeclared exports/imports for fraudulent benefits not accepted. No grounds for duty demand, confiscation, or penalties found. Appeals by Revenue dismissed, upholding adjudicating authority's orders.
Circular trading allegations of Cut and Polished Diamonds (CPD) and Gold Jewellery, over-invoicing exports of studded Gold Jewellery, misuse of Target Plus Scheme were raised. However, identical allegations were previously set aside by the Tribunal, affirmed by Supreme Court, holding no inter-relationship between parties, no circular trading. Joint DGFT order accepted no circular trading, exports valid for discharge of Advance License obligations. DGFT didn't cancel licenses or take action against respondents. Revenue's allegation of misdeclared exports/imports for fraudulent benefits not accepted. No grounds for duty demand, confiscation, or penalties found. Appeals by Revenue dismissed, upholding adjudicating authority's orders.
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