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 appeal and set aside the Commissioner's decision rejecting conversion of EOU shipping bills to DBK/DEPB shipping bills. It held the Commissioner's rejection violated principles of natural justice as no show cause notice or personal hearing was granted. The appellant had paid duty on clearances after de-bonding and closing stock, making them eligible for conversion u/s 149 of the Customs Act, 1962 as exports were from duty-paid inputs despite filing EOU shipping bills due to lack of final NOC. The CESTAT ruled the appellant was legally entitled to conversion.
The CESTAT allowed the appeal and set aside the Commissioner's decision rejecting conversion of EOU shipping bills to DBK/DEPB shipping bills. It held the Commissioner's rejection violated principles of natural justice as no show cause notice or personal hearing was granted. The appellant had paid duty on clearances after de-bonding and closing stock, making them eligible for conversion u/s 149 of the Customs Act, 1962 as exports were from duty-paid inputs despite filing EOU shipping bills due to lack of final NOC. The CESTAT ruled the appellant was legally entitled to conversion.
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