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 upheld denial of Special Additional Duty (SAD) exemption under Notification dated 17.03.2012 for imported goods valued at Rs. 73.79 Crores during 2013-2017. Appellant failed to declare goods in Delhi VAT returns and provide supporting documentation, violating notification requirements for state destination declaration and VAT registration disclosure. Principal Commissioner's findings established fraudulent practices through false declarations and non-compliance with exemption conditions. Tribunal confirmed recovery of SAD with penalties, noting appellant's failure to controvert evidence of tax evasion and misrepresentation. Appeal dismissed, affirming original order requiring payment of duties and penalties.
CESTAT upheld denial of Special Additional Duty (SAD) exemption under Notification dated 17.03.2012 for imported goods valued at Rs. 73.79 Crores during 2013-2017. Appellant failed to declare goods in Delhi VAT returns and provide supporting documentation, violating notification requirements for state destination declaration and VAT registration disclosure. Principal Commissioner's findings established fraudulent practices through false declarations and non-compliance with exemption conditions. Tribunal confirmed recovery of SAD with penalties, noting appellant's failure to controvert evidence of tax evasion and misrepresentation. Appeal dismissed, affirming original order requiring payment of duties and penalties.
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