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 held that customs duty rate is determined by the date of entry inwards at the specific port where goods are unloaded, not when vessel enters territorial waters or receives entry inwards at first port of call. Section 31 of Customs Act requires port-specific documentation for entry inwards by proper officer at each port. While goods become dutiable upon entering territorial waters, machinery provisions in Section 15 govern assessment methodology. The Tribunal rejected appellant's contention that first entry inwards dictates duty rate for subsequent ports, finding no statutory basis for this interpretation. Assessment at 7.5% based on entry inwards at Pipavav Port was upheld and appeal dismissed.
CESTAT held that customs duty rate is determined by the date of entry inwards at the specific port where goods are unloaded, not when vessel enters territorial waters or receives entry inwards at first port of call. Section 31 of Customs Act requires port-specific documentation for entry inwards by proper officer at each port. While goods become dutiable upon entering territorial waters, machinery provisions in Section 15 govern assessment methodology. The Tribunal rejected appellant's contention that first entry inwards dictates duty rate for subsequent ports, finding no statutory basis for this interpretation. Assessment at 7.5% based on entry inwards at Pipavav Port was upheld and appeal dismissed.
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