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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Court directs competent customs authority to consider petitioners' claim for waiver of export obligation and duty-saved amount for import of bamboo processing machines under Export Promotion Capital Goods Scheme within eight weeks. Interim order restraining coercive action against petitioners to remain operative until determination. Petition disposed off, without commenting on merits including promissory estoppel claim against respondents. Court finds petitioners made out case for consideration of waiver claim, particularly regarding lack of financial assistance in form of grants to industrial units in North-Eastern Region instead of returnable Technical Developmental Assistance.
Court directs competent customs authority to consider petitioners' claim for waiver of export obligation and duty-saved amount for import of bamboo processing machines under Export Promotion Capital Goods Scheme within eight weeks. Interim order restraining coercive action against petitioners to remain operative until determination. Petition disposed off, without commenting on merits including promissory estoppel claim against respondents. Court finds petitioners made out case for consideration of waiver claim, particularly regarding lack of financial assistance in form of grants to industrial units in North-Eastern Region instead of returnable Technical Developmental Assistance.
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