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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The appellant's appeal against the rejection of chargeability of Clean Energy Cess on imported metallurgical coke was dismissed. The Bills of Entry were filed in January and February 2015, but the appellant raised the issue of non-issuance of an order u/s 17(5) of the Customs Act, 1962, after more than a year from the clearance of goods. The Bills of Entry were finally assessed without re-assessment, rendering the appellant's claim of re-assessment and the requirement for an order u/s 17(5) meritless. The Commissioner's reply to the appellant's grievance letter clarified the factual position and the non-requirement of an order u/s 17(5). The Commissioner (Appeals) rightly rejected the appeal on grounds of time bar and maintainability. The impugned order passed by the Commissioner (Appeals) was upheld, and the appellant's appeal was rejected.
The appellant's appeal against the rejection of chargeability of Clean Energy Cess on imported metallurgical coke was dismissed. The Bills of Entry were filed in January and February 2015, but the appellant raised the issue of non-issuance of an order u/s 17(5) of the Customs Act, 1962, after more than a year from the clearance of goods. The Bills of Entry were finally assessed without re-assessment, rendering the appellant's claim of re-assessment and the requirement for an order u/s 17(5) meritless. The Commissioner's reply to the appellant's grievance letter clarified the factual position and the non-requirement of an order u/s 17(5). The Commissioner (Appeals) rightly rejected the appeal on grounds of time bar and maintainability. The impugned order passed by the Commissioner (Appeals) was upheld, and the appellant's appeal was rejected.
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