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 case pertains to the valuation of imported goods, specifically 1,2-Benzisothiazolin-3-ONE 85% (BIT PASTE 85%) originating from China. The appellant challenged the rejection of the declared transaction cost and the redetermination of assessable value u/s 17(5) of the Customs Act, 1962, as well as the enhancement of the assessable value based on contemporaneous import prices. The appellant submitted relevant bill of entries and literature indicating an explosion in Xiangshui Industrial Park, Yancheng, Jiangsu, which caused a temporary spike in prices from August 2019 to April 2020, before cooling down. The Appellate Tribunal found the appellant's explanation reasonable and set aside the impugned order, allowing the appeal.
The case pertains to the valuation of imported goods, specifically 1,2-Benzisothiazolin-3-ONE 85% (BIT PASTE 85%) originating from China. The appellant challenged the rejection of the declared transaction cost and the redetermination of assessable value u/s 17(5) of the Customs Act, 1962, as well as the enhancement of the assessable value based on contemporaneous import prices. The appellant submitted relevant bill of entries and literature indicating an explosion in Xiangshui Industrial Park, Yancheng, Jiangsu, which caused a temporary spike in prices from August 2019 to April 2020, before cooling down. The Appellate Tribunal found the appellant's explanation reasonable and set aside the impugned order, allowing the appeal.
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