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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AAR held that the benefit of exemption under Sl. No. 5D(b) of Notification No. 57/2017-Customs shall be available for import of inputs or parts intended for use in manufacturing display assemblies for cellular mobile phones, even if some inputs/parts get scrapped during the manufacturing process. The exemption applies to inputs/parts imported for the intended use of manufacturing display assemblies, irrespective of whether they ultimately form part of the finished product or get damaged/scrapped. The AAR rejected the contention that the advance ruling application was ineligible u/s 28E(b) of the Customs Act.
AAR held that the benefit of exemption under Sl. No. 5D(b) of Notification No. 57/2017-Customs shall be available for import of inputs or parts intended for use in manufacturing display assemblies for cellular mobile phones, even if some inputs/parts get scrapped during the manufacturing process. The exemption applies to inputs/parts imported for the intended use of manufacturing display assemblies, irrespective of whether they ultimately form part of the finished product or get damaged/scrapped. The AAR rejected the contention that the advance ruling application was ineligible u/s 28E(b) of the Customs Act.
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