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 CESTAT allowed the appeals filed by the appellant. The Tribunal held that the appellant is eligible for the benefit of the SAFTA Notification No. 99/2011-Customs dated 09.11.2011 as the appellant has fulfilled the conditions stipulated in the said notification by producing the country of origin certificate. Consequently, the impugned orders denying the benefit of the SAFTA notification to the imported goods were set aside, and the appeals were allowed.
The CESTAT allowed the appeals filed by the appellant. The Tribunal held that the appellant is eligible for the benefit of the SAFTA Notification No. 99/2011-Customs dated 09.11.2011 as the appellant has fulfilled the conditions stipulated in the said notification by producing the country of origin certificate. Consequently, the impugned orders denying the benefit of the SAFTA notification to the imported goods were set aside, and the appeals were allowed.
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