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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Appellant engaged in manufacturing cosmetics and Vaseline, classifiable under Chapters 33 and 27 of CETA respectively. Appellant paid differential duty along with duty for January 2012, fulfilling conditions of Notification No. 20/2007-CE as amended. Lower authorities rejected refund of self-credit claimed by appellant to the extent of 56% of differential duty paid, citing non-compliance with Paragraph 2A. However, appellant paid duty for August 2011 to December 2011 in January 2012 as directed, making self-credit claim valid. Impugned order rejecting refund of self-credit to the extent of Rs. 10,27,377/- set aside by Appellate Tribunal, allowing appeal.
Appellant engaged in manufacturing cosmetics and Vaseline, classifiable under Chapters 33 and 27 of CETA respectively. Appellant paid differential duty along with duty for January 2012, fulfilling conditions of Notification No. 20/2007-CE as amended. Lower authorities rejected refund of self-credit claimed by appellant to the extent of 56% of differential duty paid, citing non-compliance with Paragraph 2A. However, appellant paid duty for August 2011 to December 2011 in January 2012 as directed, making self-credit claim valid. Impugned order rejecting refund of self-credit to the extent of Rs. 10,27,377/- set aside by Appellate Tribunal, allowing appeal.
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