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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Carnet violation through non-filing of Bill of Entry - misdeclaration and misuse alleged. Notification 94/1996 applicable. Misdeclaration accepted for repair purpose, duty on repairs confirmed. No physical concealment, duties paid at import, denial of Notification benefit unjust. Redemption fine and Section 112(a) penalty set aside. Additional ground on duty determination raised for first time, being legal issue, remanded. Order modified to extent of allowing redemption fine and penalty, remanded for deciding additional ground on basic duty liability. Appeal disposed.
Carnet violation through non-filing of Bill of Entry - misdeclaration and misuse alleged. Notification 94/1996 applicable. Misdeclaration accepted for repair purpose, duty on repairs confirmed. No physical concealment, duties paid at import, denial of Notification benefit unjust. Redemption fine and Section 112(a) penalty set aside. Additional ground on duty determination raised for first time, being legal issue, remanded. Order modified to extent of allowing redemption fine and penalty, remanded for deciding additional ground on basic duty liability. Appeal disposed.
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