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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This circular clarifies the applicability of concessional duty under Import of Goods at Concessional Rate of Duty (IGCR) Rules, 2022 in certain instances. It addresses the simultaneous availment of IGCR along with Manufacture and Other Operations in Warehouse Regulations (MOOWR) scheme, and the applicability of IGCR benefit in cases involving import of certain goods specified for value-addition by MOOWR units for supply to final manufacturers of cellular mobile phones. The key points are: MOOWR units can avail IGCR exemption along with duty deferment under MOOWR simultaneously, provided conditions of both schemes are complied with. The expression "for use in manufacture of cellular mobile phones" in certain notifications does not restrict IGCR benefit only to final manufacturers; intermediate goods manufacturers under MOOWR supplying value-added goods to final cellular mobile phone manufacturers are also eligible for concessional duty under IGCR Rules, subject to fulfilling all conditions.
This circular clarifies the applicability of concessional duty under Import of Goods at Concessional Rate of Duty (IGCR) Rules, 2022 in certain instances. It addresses the simultaneous availment of IGCR along with Manufacture and Other Operations in Warehouse Regulations (MOOWR) scheme, and the applicability of IGCR benefit in cases involving import of certain goods specified for value-addition by MOOWR units for supply to final manufacturers of cellular mobile phones. The key points are: MOOWR units can avail IGCR exemption along with duty deferment under MOOWR simultaneously, provided conditions of both schemes are complied with. The expression "for use in manufacture of cellular mobile phones" in certain notifications does not restrict IGCR benefit only to final manufacturers; intermediate goods manufacturers under MOOWR supplying value-added goods to final cellular mobile phone manufacturers are also eligible for concessional duty under IGCR Rules, subject to fulfilling all conditions.
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