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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Misdeclaration regarding description and quantity of imported goods admitted. Declared goods liable for confiscation due to misdeclaration. Proper investigation not conducted to determine actual transaction value. No admissible evidence for contemporaneous imports. Declared value accepted for declared goods. Appellant failed to furnish evidence for value of excess 140 cartons. Assessable value of excess cartons upheld at Rs.3,56,510/-. Redemption fine reduced to Rs.35,000/- and penalty to Rs.20,000/-. Appeal partly allowed.
Misdeclaration regarding description and quantity of imported goods admitted. Declared goods liable for confiscation due to misdeclaration. Proper investigation not conducted to determine actual transaction value. No admissible evidence for contemporaneous imports. Declared value accepted for declared goods. Appellant failed to furnish evidence for value of excess 140 cartons. Assessable value of excess cartons upheld at Rs.3,56,510/-. Redemption fine reduced to Rs.35,000/- and penalty to Rs.20,000/-. Appeal partly allowed.
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