Toy balloon tariff classification: functional heading prevails over residual rubber and festive article headings, supporting penalties for deliberate ...
Customs valuation using comparable contemporaneous imports can displace declared value, while missing speaking orders require pursuit before competent...
Foreign customs declarations and importer admissions established undervaluation, supporting sequential value redetermination, differential duty, and m...
Customs seizure safeguards prevent detention-based limitation avoidance and invalidate provisional release conditions for imported vehicles under an i...
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HELD: DRP excluded forex losses and gains from operating income computation based on safe harbor rules. However, both being of similar nature, forex gains to be treated as operating income like losses. Thirdware Solutions Ltd.'s inclusion or exclusion as comparable remitted to TPO for adjudication based on substantiation. Akshay Software Technologies Ltd. to be accepted as comparable. Infosys BPO Ltd. excluded as services offered not comparable to assessee's routine services. BNR Udyog Ltd. excluded as engaged in KPO services. Informed Technologies India Ltd. to be included as comparable under ITeS segment. Ace BPO Services Ltd.'s inclusion directed if current data available. Disallowance u/s 40(a)(i) for want of TDS u/s 195 on payments to GTE-Overseas Corporation restored to AO for consistent stand.
HELD: DRP excluded forex losses and gains from operating income computation based on safe harbor rules. However, both being of similar nature, forex gains to be treated as operating income like losses. Thirdware Solutions Ltd.'s inclusion or exclusion as comparable remitted to TPO for adjudication based on substantiation. Akshay Software Technologies Ltd. to be accepted as comparable. Infosys BPO Ltd. excluded as services offered not comparable to assessee's routine services. BNR Udyog Ltd. excluded as engaged in KPO services. Informed Technologies India Ltd. to be included as comparable under ITeS segment. Ace BPO Services Ltd.'s inclusion directed if current data available. Disallowance u/s 40(a)(i) for want of TDS u/s 195 on payments to GTE-Overseas Corporation restored to AO for consistent stand.
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