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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Whether anti-dumping duty (ADD) is applicable on color coated aluminum coils imported as coated with Styrene/Butyl Methacrylate Copolymer, other than PE/PVDF. - The Tribunal found that the Trade TRU had clarified through Circular No.45/2017-Customs (ADD) that "color coated aluminum foil with either PE (Polyester) coating or PVDF (Fluorine-carbon), coating falling under CTH 7607" is excluded from the scope of the product under consideration (PUC) for ADD. 3. However, the Tribunal observed that the TRU had added the words "with either PE (Polyester) coating or PVDF (Fluorine-carbon), coating falling under CTH 7607" while issuing the circular, which led to the revenue restricting the exclusion. 4. The Tribunal noted that the Principal Bench had previously held that the product is not manufactured in India, and the Designated Authority had supported excluding color coated aluminum foil from the scope of ADD. 5. The Tribunal found merit in the appellant's contention that the purpose of imposing ADD is to safeguard the interests of the domestic industry.
Whether anti-dumping duty (ADD) is applicable on color coated aluminum coils imported as coated with Styrene/Butyl Methacrylate Copolymer, other than PE/PVDF. - The Tribunal found that the Trade TRU had clarified through Circular No.45/2017-Customs (ADD) that "color coated aluminum foil with either PE (Polyester) coating or PVDF (Fluorine-carbon), coating falling under CTH 7607" is excluded from the scope of the product under consideration (PUC) for ADD. 3. However, the Tribunal observed that the TRU had added the words "with either PE (Polyester) coating or PVDF (Fluorine-carbon), coating falling under CTH 7607" while issuing the circular, which led to the revenue restricting the exclusion. 4. The Tribunal noted that the Principal Bench had previously held that the product is not manufactured in India, and the Designated Authority had supported excluding color coated aluminum foil from the scope of ADD. 5. The Tribunal found merit in the appellant's contention that the purpose of imposing ADD is to safeguard the interests of the domestic industry.
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