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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The court held that for amendment of Import General Manifest (IGM) due to change in consignee, the procedure prescribed in paragraph 3(c) and (e) of Customs Circular No. 14/2017-Customs dated 11th April 2017 must be complied with. The court relied on a previous decision in ETG AGRI INDIA PVT. LTD. VERSUS UNION OF INDIA AND OTHERS, where it was directed that the concerned authority empowered to consider the application for amendment in IGM should decide the application, subject to the condition of the petitioner executing an indemnity bond in favor of the authorities, indemnifying them against claims and protests raised by private parties regarding the subject goods. Accordingly, the petition was disposed of.
The court held that for amendment of Import General Manifest (IGM) due to change in consignee, the procedure prescribed in paragraph 3(c) and (e) of Customs Circular No. 14/2017-Customs dated 11th April 2017 must be complied with. The court relied on a previous decision in ETG AGRI INDIA PVT. LTD. VERSUS UNION OF INDIA AND OTHERS, where it was directed that the concerned authority empowered to consider the application for amendment in IGM should decide the application, subject to the condition of the petitioner executing an indemnity bond in favor of the authorities, indemnifying them against claims and protests raised by private parties regarding the subject goods. Accordingly, the petition was disposed of.
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