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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Petition challenging seizure memorandum, show cause notice (SCN), and lookout notice issued regarding mis-declaration of imported goods dismissed. SCN issued u/s 28(4) read with Sections 124 and 110AA of Customs Act, citing suppression of facts and willful misstatement. Commissioner of Customs qualifies as "Proper Officer" u/s 2(34) to initiate proceedings u/s 28(4). SCN issued within 5-year limitation period u/s 28(4). Lookout notice challenge maintainable only by individual to whom issued. Challenge to seizure memorandum rejected on grounds of laches. Petition unsustainable.
Petition challenging seizure memorandum, show cause notice (SCN), and lookout notice issued regarding mis-declaration of imported goods dismissed. SCN issued u/s 28(4) read with Sections 124 and 110AA of Customs Act, citing suppression of facts and willful misstatement. Commissioner of Customs qualifies as "Proper Officer" u/s 2(34) to initiate proceedings u/s 28(4). SCN issued within 5-year limitation period u/s 28(4). Lookout notice challenge maintainable only by individual to whom issued. Challenge to seizure memorandum rejected on grounds of laches. Petition unsustainable.
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