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 dismissed revenue's appeal regarding customs duty recovery from 100% EOU for raw materials used in DTA clearances. The tribunal interpreted exemption notifications N/N. 12/2012-Cus and 12/2012-CE liberally, holding that the phrase "for the manufacture of" encompasses all items directly or indirectly consumed in manufacturing mobile handsets and accessories. Following SC precedent in Jawahar Mills, the tribunal ruled that the exemption covers all manufacturing inputs, not merely identifiable components. The classification of goods as components or accessories was deemed irrelevant for determining notification applicability. The benefit extends to all goods used in manufacturing mobile parts and battery chargers, regardless of their direct incorporation in final products.
CESTAT dismissed revenue's appeal regarding customs duty recovery from 100% EOU for raw materials used in DTA clearances. The tribunal interpreted exemption notifications N/N. 12/2012-Cus and 12/2012-CE liberally, holding that the phrase "for the manufacture of" encompasses all items directly or indirectly consumed in manufacturing mobile handsets and accessories. Following SC precedent in Jawahar Mills, the tribunal ruled that the exemption covers all manufacturing inputs, not merely identifiable components. The classification of goods as components or accessories was deemed irrelevant for determining notification applicability. The benefit extends to all goods used in manufacturing mobile parts and battery chargers, regardless of their direct incorporation in final products.
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