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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CESTAT affirmed customs duty liability and penalty against custodian for pilfered imported refrigerant gas cylinders while in custody. Following precedent from Delhi HC, tribunal held custodian responsible u/s 45 of Customs Act read with Regulation 6 of Handling of Cargo Regulations for safe custody until clearance. Show cause notice issued on 18.12.2013 was within limitation period from discovery of pilferage on 27.06.2013. Penalty u/s 117 upheld as custodian failed safekeeping obligations. Appellant's duty liability confirmed since goods requiring NOC from Chief Controller of Explosives were documented present during first check but subsequently found missing from sealed container.
CESTAT affirmed customs duty liability and penalty against custodian for pilfered imported refrigerant gas cylinders while in custody. Following precedent from Delhi HC, tribunal held custodian responsible u/s 45 of Customs Act read with Regulation 6 of Handling of Cargo Regulations for safe custody until clearance. Show cause notice issued on 18.12.2013 was within limitation period from discovery of pilferage on 27.06.2013. Penalty u/s 117 upheld as custodian failed safekeeping obligations. Appellant's duty liability confirmed since goods requiring NOC from Chief Controller of Explosives were documented present during first check but subsequently found missing from sealed container.
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