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 appellant challenged the notification extending the restriction on imports of green peas and yellow peas up to 31.12.2018, as the initial restriction was only until 30.06.2018. The Rajasthan High Court initially stayed the operation of the extended notification, which was later upheld by the Supreme Court. Although the imports during 22.10.2018 to 28.12.2018 were held restricted, the Tribunal took a sympathetic view considering the appellant was a regular importer, the gap of three months without restrictions, and the legal challenge. The redemption fine and penalty imposed by the Adjudicating Authority were reduced by the Commissioner (Appeals), and the Tribunal disposed of the appeals filed by the Revenue and the cross-objection filed by the Respondent.
The appellant challenged the notification extending the restriction on imports of green peas and yellow peas up to 31.12.2018, as the initial restriction was only until 30.06.2018. The Rajasthan High Court initially stayed the operation of the extended notification, which was later upheld by the Supreme Court. Although the imports during 22.10.2018 to 28.12.2018 were held restricted, the Tribunal took a sympathetic view considering the appellant was a regular importer, the gap of three months without restrictions, and the legal challenge. The redemption fine and penalty imposed by the Adjudicating Authority were reduced by the Commissioner (Appeals), and the Tribunal disposed of the appeals filed by the Revenue and the cross-objection filed by the Respondent.
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