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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Imported goods classified under Customs Tariff Item (CTI) 8714 10 90 or 8714 91 00 - General Rules of Interpretation applied for classification - Goods rightly classified under 8714 10 90 as parts of motorcycle frames, not entitled to exemption under Notification No. 50/2017-CUS - Confiscation of goods u/s 111(m) and redemption fine set aside as classification by importer during self-assessment differing from officer's view not ground for confiscation - Penalties u/ss 112 and 114AA on appellant and employee set aside for lack of evidence of false declaration - Appeal disposed.
Imported goods classified under Customs Tariff Item (CTI) 8714 10 90 or 8714 91 00 - General Rules of Interpretation applied for classification - Goods rightly classified under 8714 10 90 as parts of motorcycle frames, not entitled to exemption under Notification No. 50/2017-CUS - Confiscation of goods u/s 111(m) and redemption fine set aside as classification by importer during self-assessment differing from officer's view not ground for confiscation - Penalties u/ss 112 and 114AA on appellant and employee set aside for lack of evidence of false declaration - Appeal disposed.
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