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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Goods classified as Aluminium Scrap Tassel under CTH 76020010 instead of Coils of Aluminium Wire under 76051100. Chartered Engineer Certificate confirmed goods not in primary form of coils, but Aluminium Scrap Tassel as per ISRI specification including old, unalloyed Aluminium wire and cable with defects. Enhancement of value based on NIDB data not sustainable as goods correctly classified as Aluminium Scrap. Tribunal set aside the impugned order, allowing the appeal.
Goods classified as Aluminium Scrap Tassel under CTH 76020010 instead of Coils of Aluminium Wire under 76051100. Chartered Engineer Certificate confirmed goods not in primary form of coils, but Aluminium Scrap Tassel as per ISRI specification including old, unalloyed Aluminium wire and cable with defects. Enhancement of value based on NIDB data not sustainable as goods correctly classified as Aluminium Scrap. Tribunal set aside the impugned order, allowing the appeal.
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