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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Valuation and classification of imported goods, specifically motor controllers and electric tricycle spare parts. The key issues addressed are the enhancement of CIF value, rejection of the declared value, and the classification of the motor controller under either CTH 8503 0090 or CTH 8708 9900. The Tribunal held that based on the explanatory notes to Section XVII and the notes to CTH 8503, the motor controllers are rightly classifiable under CTH 8503 0090 as claimed by the importer in the respective bills of entry. Consequently, the Revenue Appeals were dismissed. The Tribunal's decision was based on a previous ruling in a related case involving the same appellant.
Valuation and classification of imported goods, specifically motor controllers and electric tricycle spare parts. The key issues addressed are the enhancement of CIF value, rejection of the declared value, and the classification of the motor controller under either CTH 8503 0090 or CTH 8708 9900. The Tribunal held that based on the explanatory notes to Section XVII and the notes to CTH 8503, the motor controllers are rightly classifiable under CTH 8503 0090 as claimed by the importer in the respective bills of entry. Consequently, the Revenue Appeals were dismissed. The Tribunal's decision was based on a previous ruling in a related case involving the same appellant.
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